First Blood Associates, Richard M. Greenberg, Tax Matters Partner, et al. - Page 3

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          A. Frederick Greenberg.3  Respondent began an examination of the            
          partnership at some point in the mid-1980's as part of a national           
          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 the partnership,              
          retained Peter L. Faber (Mr. Faber) to represent the partners at            
          the partnership level during respondent's examination.4  Mr.                
          Faber also represented the partners at the partnership level upon           
          filing the petitions in the cases at docket Nos. 623-92, 13014-             
          92, and 15641-92.                                                           

                    On its partnership returns for the years in issue,                
          First Blood claimed loss deductions arising from the alleged                
          purchase of the film "First Blood" starring Sylvester Stallone.             
          We note that whether the partnership obtained the benefits and              
          burdens of ownership in the film is not here at issue, but has              
          formed the basis for considerable securities litigation.  See,              
          e.g., Block v. First Blood Associates, 988 F.2d 344, 347 (2d Cir.           
          1993), and cases cited therein.                                             
                    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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