Crop Associates-1986, Frederick H. Behrens, Tax Matters Partner - Page 6




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          but neither were any of the 1500 other limited partners affected            
          by any AMCOR-related cases then before the Court.  Following a              
          hearing on the motion to stay, we granted the motion to stay and            
          the proceedings were stayed until April 3, 1991 (the stay).                 
               Upon a motion by respondent on April 1, 1991, the stay was             
          extended to October 3, 1991 (the extension).  The stay was                  
          lifted, however, upon the motion of the petitioning partners,               
          filed April 9, 1991, requesting that we reconsider the extension.           
          The petitioning partners argued on behalf of themselves and the             
          other limited partners of the partnership (together, the limited            
          partners).  They argued that, although petitioner was technically           
          a party to this case, see section 6226(c)(1) and Rule 247(a), he            
          was not a participating partner, and the real parties in interest           
          were the limited partners, who held 99 percent of the partnership           
          interests.  The petitioning partners argued:                                
               [T]he limited partners * * * had no involvement in the                 
               activities and events which give rise to Respondent’s                  
               criminal investigation.  The * * * [limited partners]                  
               are neither the actors in nor the targets of alleged                   
               criminality – they are passive investors who seek only                 
               the prompt adjudication of civil tax claims asserted                   
               and initiated by the Respondent * * *                                  
               The stay was lifted on June 19, 1991, and respondent filed             
          the answer on August 19, 1991.                                              
               On May 1, 1992, we set this case for trial at the trial                
          session scheduled to commence in Washington, D.C., on October 5,            
          1992.                                                                       






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