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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011