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Kletnick did not believe that petitioners were covered under the
settlement agreement for all years in which they claimed Arbitrage
Management partnership loss deductions, this is nowhere reflected
in the terms of the agreement. In sum, the blanket settlement
offer that petitioners accepted3 was an offer to settle all years
2(...continued)
the Arbitrage Management settlements were intended to apply to
all years in which there were Arbitrage Management investments.
William L. Blagg, one of respondent's counsel in Manko v.
Commissioner, T.C. Memo. 1995-10, made the following comments
during that trial:
MR. BLAGG: All that we wish to clarify is
that the hearing only covered the years 1982
and 1983 and the letter that is -- the
January 21st letter only deals with the
docketed cases, which did not include the
years 1982 and 1983.
* * * * * * *
THE COURT: But the settlement, as I
understand it, relates to all the years,
docketed and nondocketed, for everybody else.
Is that not correct?
MR. BLAGG: But the settlement is negotiated
on -- the testimony has been that the
settlement was negotiated on that basis;
that's correct.
THE COURT: Right. And you have reason to
believe it wasn't?
MR. BLAGG: No, I do not.
3 Mr. Kletnick testified that he was unaware that the
list enclosed with his Jan. 21, 1988, letter to the Court
(continued...)
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