Transpac Drilling Venture 1982-21, Asher Fensterheim, Charles L. Pincus, Thomas D. Callahan, Donald W. Dvorak, and Thomas J. Williams, Partners Other Than The Tax Matters Partner, et al. - Page 2

                       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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