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. RespondentPage: 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