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project focusing on the various partnerships of the Greenberg
Brothers (the Greenberg Brothers project). Richard M. Greenberg,
who was then the tax matters partner (TMP) of Cinema '85,
retained attorney Peter L. Faber (Mr. Faber) to represent the
partners at the partnership level during respondent's
examination.3 Mr. Faber also represented the partners at the
partnership level upon filing the petition in this case.
Mr. Newman was a limited partner in Cinema '85 during the
partnership taxable years in issue. Mr. Newman has elected to
participate in these proceedings pursuant to section 6226(c)(2)
and Rule 245(b).
Joseph F. Long (Mr. Long), an attorney in respondent's
District Counsel office in Hartford, Connecticut, represented
respondent in the settlement negotiations for the Greenberg
Brothers project. After Mr. Long was assigned to the project, he
and Mr. Faber discussed the possibility of settling the Greenberg
Brothers partnership cases by a settlement at the partnership
level.
On or about August 6, 1990, Mr. Long wrote to Mr. Faber
regarding the Greenberg Brothers project, listing Cinema '85 in
the subject portion of the letter. In the letter, Mr. Long
3
Richard M. Greenberg became disqualified from acting as
the TMP when an involuntary petition in bankruptcy was filed
against him in January 1994. See sec. 6231(c); sec.
301.6231(a)(7)-1(l)(1)(iv), Proced. & Admin. Regs.; sec.
301.6231(c)-7T, Temporary Proced. & Admin. Regs., 52 Fed. Reg.
6793 (Mar. 5, 1987).
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