- 4 - involved in the test cases of Krause v. Commissioner, supra, and accordingly that the limited partners of the Denver-based partnerships who had not settled their cases with respondent were to be bound by the opinion in Krause. The settlements that petitioners herein entered into and that they now seek to set aside are consistent with our decisions in Krause and the above- cited related cases (namely, no deductions are to be allowed to the taxpayers relating to their investments in the Elektra Hemisphere tax shelters, and the taxpayers are not to be held liable for additions to tax or penalties other than increased interest under section 6621(c) or its predecessor section 6621(d)) (hereinafter referred to as the no-cash settlements). Beginning in 1986, respondent made a number of offers to the investors-taxpayers to settle tax adjustments that respondent had determined involving the Elektra Hemisphere tax shelters, including those in the Denver-based partnerships. Over the years, respondent’s settlement position with regard to the issues involved in the Elektra Hemisphere tax shelters has changed, and terms of the settlement offers that respondent has made available to investors have changed accordingly. As time progressed and as the test cases approached trial, respondent’s settlement position generally became more favorable to respondent and less favorable to the investor-taxpayers. Each of respondent’s various settlement positions contained time deadlines or terminationPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011