Crop Associates-1986, Frederick H. Behrens, Tax Matters Partner - Page 20




                                       - 20 -                                         
               3.  Documents were unlawfully seized pursuant to a defective           
               search warrant.                                                        
          Petitioner further agreed that the harms of which he complains              
          are (1) prejudice to petitioner in presenting his case and                  
          (2) the additional interest on any deficiency that would result             
          to petitioner on account of respondent’s causing a delay in                 
          resolving the case.                                                         
          II.  Petitioner’s Memoranda                                                 
               Petitioner filed a post-hearing memorandum in support of the           
          motion (petitioner’s memorandum) and incorporated into the motion           
          the memorandum filed March 24, 1995, by the petitioning partners            
          in support of the 1995 misconduct motion (petitioning partners’             
          memorandum).  In the introduction to petitioner’s memorandum,               
          petitioner states:  “The pervasive nature of Respondent’s                   
          misconduct has caused infringements of the TMP’s, AMCOR’s and the           
          AMCOR’s partnerships’ [including Crop Associates-1986]                      
          constitutional rights”.  Both petitioner’s memorandum and the               
          petitioning partners’ memorandum complain of “a complex weave of            
          especially prejudicial illegal and improper acts”.  In each                 
          memorandum, the complaint is followed by a list of actions taken            
          by respondent and complained of by the author of the memorandum.            
          The lists are different, and we assume that petitioner no longer            











Page:  Previous  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  29  Next

Last modified: May 25, 2011