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Partnership’s TMP, pursuant to respondent’s appointment under
section 6231(a)(7). Neither Mr. Tauskey nor respondent furnished
a copy of the FPAAs or otherwise provided notice of the
partnership action to petitioners.
The partnership action was settled on April 25, 2000. The
settlement, predicated on the stipulation of the partnership
transactions as being devoid of economic substance and a bona
fide profit motive, partially disallowed the partnership loss and
deduction items for 1985, and denied the entirety of the
partnership losses and deductions for 1986. The TMP, James A.
Grever (appointed to succeed the deceased Mr. Tauskey) was an
individual investor, unaffiliated with the Partnership’s
originator or managerial agents, and, therefore, could not
ascertain the identities of the remaining partners not
participating in the partnership action. Respondent compiled a
schedule of the known nonparticipating partners, which included
petitioners and their contact information. On October 20, 2000,
the Court granted Mr. Grever’s motion for an order directing
service of any notice of settlement on the aforementioned
nonparticipating partners, and providing Mr. Grever contingent
relief from any liability otherwise occasioned by his relying
solely on respondent’s schedule in the discharge of the notice
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