Charles Deverna - Page 5

                                        - 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’s                  






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next

Last modified: May 25, 2011