Greenberg Brothers Partnership #12, a.k.a. Lone Wolf McQuade Associates, and Richard M. Greenberg, Tax Matters Partner - Page 2

                                        - 2 -                                         

          taxable years in issue Lone Wolf is subject to the unified audit            
          and litigation procedures of sections 6221 through 62311 enacted            
          by the Tax Equity & Fiscal Responsibility Act of 1982 (TEFRA),              
          Pub. L. 97-248, sec. 402(a), 96 Stat. 648.  They further agree              
          that a timely petition was filed and, accordingly, this Court has           
          jurisdiction over this case.  The Nirschls, however, argue that             
          they entered into a settlement agreement with respondent which              
          converted their partnership items to nonpartnership items and,              
          with respect to them, ousted this Court's jurisdiction pursuant             
          to sections 6226(d)(1)(A) and 6231(b)(1)(C).  The issue is                  
          whether the Nirschls and respondent entered into a binding                  
          settlement agreement with respect to adjustments relating to the            
          Nirschls' investment in Lone Wolf for the 1983 through 1986                 
          partnership taxable years.                                                  
                                  FINDINGS OF FACT                                    
               Lone Wolf is one of a number of partnerships formed to                 
          purchase and exploit the rights to certain films.  The general              
          partners of those partnerships were Richard M. Greenberg and/or             
          A. Frederick Greenberg.2  Respondent began an examination of the            

               1                                                                      
                    Unless otherwise indicated, all section references are            
          to the Internal Revenue Code in effect for the years in issue,              
          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.                                                              
               2                                                                      
                    On its partnership returns for the years in issue, Lone           
          Wolf claimed loss deductions based on the alleged purchase of the           
          films "Lone Wolf McQuade" starring Chuck Norris, and "Strange               
                                                             (continued...)           




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

Last modified: May 25, 2011