Estate of James T. Campion, Deceased, Leona Campion, Executrix, et al. - Page 6

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          available to all taxpayers at all points in time the most                   
          favorable settlement terms that were offered to any taxpayer.               
               More specifically, petitioners allege --                               

               (1) that the settlements that were agreed to in the                    
               instant cases were premised on the erroneous fact that                 
               no better settlements were available to the taxpayers;                 
               (2) that because of the express language of section                    
               6224(c)(2), the TEFRA partnership settlement procedures                
               apply to partnerships for all years, once partnerships                 
               are subject to the general TEFRA partnership provisions                
               for any year;                                                          
               (3) that, during 1994 and later years, when petitioners                
               entered into their settlements for the pre-TEFRA years                 
               (1979-1982), petitioners and their counsel allegedly                   
               were not notified by respondent of the prior, more                     
               favorable cash settlements that other taxpayers during                 
               1986, 1987, and 1988 had agreed to; and                                
               (4) that (because of (2) above) the Elektra/Hemisphere                 
               tax shelter partnerships’ pre-TEFRA years effectively                  
               became, or should be treated as becoming, subject to                   
               the TEFRA partnership settlement procedures.  Thus,                    
               petitioners herein allege that during 1994 and later                   
               years they should have been allowed to settle their                    
               cases consistent with the most favorable settlement                    
               terms offered to any other taxpayers at any time.                      

               Petitioners allege the existence of "a pervasive and                   
          manufactured conspiracy" among respondent’s counsel to deprive              
          them and other taxpayers of the TEFRA settlement procedures for             
          pre-TEFRA years.  Petitioners allege that the defective                     
          settlement procedures that were utilized to settle the instant              
          cases also affected some 2,000 other settlement agreements and a            
          total of 12,000 case dispositions.                                          





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