3
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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