- 2 - Petitioners (investors in the so-called Elektra Hemisphere tax shelters) move for leave to file motions under Rule 162 to vacate final decisions that have been entered herein and to require respondent now to enter into revised settlement agreements with petitioners (that reflect settlement terms available from respondent to investors in 1986, 1987, and 1988). Held: Petitioners’ motions are denied. Declan J. O'Donnell, for petitioners. Michael W. Bitner, for respondent. OPINION SWIFT, Judge: This matter is before the Court in these consolidated cases on petitioners’ motions for leave to file motions to vacate decisions with attached motions to vacate under Rule 162. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure, and all section references are to the Internal Revenue Code for the years in issue. In each of these cases, petitioners and respondent settled all issues, and final decisions have been entered. The 90-day appeal period has expired, and petitioners now seek orders from the Court vacating the decisions and requiring respondent to enter into new settlement agreements with petitioners that wouldPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011