Mayer and Ninette Stiskin - Page 1

                                 T.C. Memo. 1996-306                                  

                               UNITED STATES TAX COURT                                

                      MAYER AND NINETTE STISKIN, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 36140-86.                     Filed July 8, 1996.           

                    In 1980, P became a limited partner in a tax                      
               shelter limited partnership.  In 1986, the Commissioner                
               issued a notice of deficiency for 1982 relating to                     
               deductions claimed in connection with the limited                      
               partnership, and Ps filed a petition in this Court.  In                
               1988, 2 years after the case was docketed in this                      
               Court, Ps signed a Form 906, "Closing Agreement on                     
               Final Determination Covering Specific Matters."                        
                    Held:  The closing agreement did not oust this                    
               Court of jurisdiction.                                                 
                    Held, further, the closing agreement itself was in                
               any event void because signed on behalf of the IRS by                  
               an Associate Chief of Appeals who did not have the                     
               authority to enter into a closing agreement in a case                  
               docketed in this Court.  Delegation Order No. 97 (Rev.                 
               19), 47 Fed. Reg. 19842 (May 7, 1982); Delegation Order                
               No. 225 (Rev. 1), 52 Fed. Reg. 13008 (Apr. 20, 1987).                  

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