Estate of James T. Campion, Deceased, Leona Campion, Executrix, et al. - Page 4

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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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