First Blood Associates, Richard M. Greenberg, Tax Matters Partner, et al. - Page 2

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          jurisdiction.  The underlying dispute arises from the Goodwins'             
          interest in First Blood Associates (First Blood or the                      
          partnership).  The parties agree that for the partnership taxable           
          years in issue the partnership is subject to the unified audit              
          and litigation procedures of sections 6221 through 62312 enacted            
          by the Tax Equity & Fiscal Responsibility Act of 1982 (TEFRA),              
          Pub. L. 97-248, sec. 402(a), 96 Stat. 648.  They further agree              
          that timely petitions were filed and, accordingly, this Court has           
          jurisdiction over these cases.  The Goodwins, however, argue that           
          they entered into a settlement agreement with respondent which              
          converted their partnership items to nonpartnership items and,              
          with respect to them, ousted this Court's jurisdiction pursuant             
          to sections 6226(d)(1)(A) and 6231(b)(1)(C).  The issue is                  
          whether the Goodwins and respondent entered into a binding                  
          settlement agreement with respect to adjustments relating to the            
          Goodwins' investment in First Blood for the 1983 through 1990               
          partnership taxable years.                                                  
                                  FINDINGS OF FACT                                    
               First Blood is one of a number of partnerships formed to               
          purchase and exploit the rights to certain films.  The general              
          partners of those partnerships were Richard M. Greenberg and/or             

                    Unless otherwise indicated, all sections references are           
          to the Internal Revenue Code in effect for the years in issue,              
          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.                                                              

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