Transpac Drilling Venture 1982-08, Albert D. & Luella L. Eshelman, A Partner Other Than The Tax Matters Partner - Page 2

          Background                                                                  
          Transpac Drilling Venture 1982-08 (Transpac) is a                           
          partnership subject to the unified partnership audit and                    
          litigation procedures set forth in sections 6221 through 6233.              
          Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L.           
          97-248, sec. 402(a), 96 Stat. 648.                                          
               On March 23, 1990, respondent issued three separate notices            
          of final partnership administrative adjustment (FPAA) to                    
          Transpac's tax matters partner (TMP) setting forth adjustments to           
          Transpac's partnership items for 1982, 1983, and 1984.  On April            
          10, 1990, respondent mailed copies of the FPAA's described above            
          to Transpac partners Albert D. and Luella L. Eshelman                       
          (petitioners).                                                              
               On August 17, 1990, Charles Haydon, Esq. (Mr. Haydon) filed            
          a timely petition for readjustment on behalf of petitioners, as             
          partners other than the TMP, contesting the FPAA's described                
          above.2  Sec. 6226(b).  Paragraph 7 of the petition states:  "The           
          name and address of the tax matters partner, so far as known, are           


          2 The petition includes an allegation that Transpac's                       
          principal place of business is Scarsdale, N.Y.  Respondent's                
          answer to the petition includes a denial of this allegation for             
          lack of sufficient information.  Sec. 7482(b)(1)(E) provides that           
          an appeal in this case will lie with the Court of Appeals for the           
          circuit in which the partnership's principal place of business is           
          located.  Considering the limited circumstances under which this            
          Court may vacate a final decision (as more fully discussed                  
          below), we do not find it necessary to determine Transpac's                 
          principal place of business in order to rule on the pending                 
          motion.                                                                     




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