19
Fensterheim developed a well thought-out scheme to slip one (or
two) by respondent. It did not work.
We hold that Fensterheim and respondent did not enter into
settlement agreements for Transpac partnerships 1982-15 and 1982-
21 for the taxable years 1982, 1983, and 1984, and Fensterheim
remains a party to these partnership proceedings.
To reflect the foregoing,
An Order will be issued denying
Fensterheim's Motion to Dismiss.
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