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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 termination
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