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reflect settlement terms that were available to investors in the
so-called Elektra Hemisphere tax shelters in 1986, 1987, and
1988.
The particular years before us in these consolidated cases
are 1979, 1980, 1981, and 1982 -- years prior to the effective
date of the Tax Equity and Fiscal Responsibility Act of 1982
(TEFRA), Pub. L. 97-248, 96 Stat. 324, partnership provisions.
In Vulcan Oil Tech. Partners v. Commissioner, 110 T.C. (1998),
with regard to 1983 and later years that are subject to the TEFRA
partnership provisions, other investors in the Elektra Hemisphere
tax shelters have filed motions similar to the instant motions.
Our opinion in Vulcan is also filed this date.
The underlying tax shelter investments that are involved in
these consolidated cases are referred to as investments in
certain Denver-based limited partnerships and were related to the
Elektra Hemisphere tax shelters that were the subject of
litigation in this Court in Krause v. Commissioner, 99 T.C. 132
(1992), affd. sub nom. Hildebrand v. Commissioner, 28 F.3d 1024
(10th Cir. 1994); Acierno v. Commissioner, T.C. Memo. 1997-441,
Karlsson v. Commissioner, T.C. Memo. 1997-432; and Vanderschraaf
v. Commissioner, T.C. Memo. 1997-306.
In Acierno v. Commissioner, supra, we found that the Denver-
based partnerships that are involved in the instant cases were
similar to the Manhattan and Wichita partnerships that were
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