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 3

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               During the taxable year 1981, Fensterheim was a partner in             
          Transpac Drilling Venture 1981-10 (Transpac partnership 1981-10),           
          docket No. 9906-90.  Fensterheim's interest in Transpac                     
          partnership 1981-10 resulted in a separate Tax Court case in                
          which a decision has been entered.  Fensterheim's Motion to                 
          Dismiss now before the Court does not involve Transpac                      
          partnership 1981-10.  Transpac partnership 1981-10 was not                  
          subject to the unified audit and litigation procedures set forth            
          in sections 6221 through 6233 (the TEFRA provisions) enacted by             
          the Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. 97-           
          248, sec. 402(a), 96 Stat. 648, and amended retroactively by the            
          Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 714(p)(1), 98           
          Stat. 494, 964.                                                             
               During the taxable years 1982, 1983, and 1984, Fensterheim             
          was a partner in Transpac Drilling Ventures 1982-1, 1982-15, and            
          1982-21 (Transpac partnerships), and these Transpac partnerships            
          were subject to the TEFRA provisions.  The principal place of               
          business of the Transpac partnerships was 230 Park Avenue, New              
          York, New York.  Fensterheim and respondent agree that they have            
          settled Fensterheim's interests in the items related to Transpac            
          partnership 1982-1 for each of the years in issue.  Items                   
          relating to Transpac partnerships 1982-15 and 1982-21 remain at             
          issue for purposes of Fensterheim's Motion to Dismiss.                      
               Transpac partnerships 1982-1, 1982-15, and 1982-21 were part           
          of respondent's Transpac national litigation project.  Respondent           




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