- 5 - was different. As a result of these differences, each partnership, and then each limited partner, was addressed one at a time. Before the individual computations could be done, the IRS had to determine: (a) How much cash was contributed by each limited partner; (b) in which tax years the contributions were made; (c) whether the limited partners received any distributions; (d) in which tax years any distributions were made; (e) whether each limited partner contributed cash towards a “Note Settlement Agreement” in 1987; (f) and how much cash, if any, was contributed by each limited partner towards the Note Settlement Agreement in 1987. The answer to each of the six questions was needed to determine the deficiencies and/or credits for each of the nearly 1,000 limited partners in the 20 TEFRA partnerships. After the above was determined, a computation had to be prepared by an Appeals officer from the Manhattan Appeals Office before a proposed decision document could be submitted to the Court. On October 12, 1993, Lerner sent to “All Swanton TEFRA Partners” a letter notifying them of the settlement with the IRS (October 1993 letter). The letter, in part, stated that the IRS would begin sending decision documents and closing agreements to the partners within 1 to 2 months after October 1993. The letter further stated that, within 1 year after the partnership’sPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011