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MEMORANDUM FINDINGS OF FACT AND OPINION
CLAPP, Judge: These cases are before us on Asher
Fensterheim's Motion to Dismiss for Lack of Jurisdiction as to
Asher Fensterheim and to Strike (Fensterheim's Motion to Dismiss)
on the ground that he has entered into settlement agreements with
respondent pursuant to section 6224(c)(1) and, as a result, is no
longer a party to these proceedings pursuant to section
6226(d)(1)(A). The issue for decision is whether Asher
Fensterheim (Fensterheim) entered into settlement agreements with
respondent in Transpac Drilling Ventures 1982-15 and 1982-21 for
the taxable years 1982, 1983, and 1984. We hold that he did not.
All section references are to the Internal Revenue Code as
in effect for the years in issue, and all Rule references are to
the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
These cases are consolidated for trial, briefing, and
opinion for the limited purpose of disposing of Fensterheim's
Motion to Dismiss. Some of the facts have been stipulated and
are found accordingly. We incorporate by reference the
stipulations of facts and attached exhibits.
Asher Fensterheim, resided in White Plains, New York, when
the petitions for readjustment of partnership items in these
cases were filed. Fensterheim is an attorney who specializes in
commercial law and insolvency.
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