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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 would
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Last modified: May 25, 2011