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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
2
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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Last modified: May 25, 2011