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petitioners in a non-TEFRA proceeding before this Court at docket
No. 17752-85, which addressed a tax controversy arising from
their investment in First Blood for the 1982 partnership taxable
year. Thomas E. Redding (Mr. Redding) was the Goodwins' counsel
of record in docket No. 17752-85 as well as in the cases now
before the Court.7
Joseph F. Long (Mr. Long), an attorney in respondent's
District Counsel office in Hartford, Connecticut, represented
respondent in settlement negotiations for the Greenberg Brothers
project. Mr. Long was also counsel of record for respondent in
docket No. 17752-85. After Mr. Long was assigned to the
Greenberg Brothers 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 First Blood in
the subject portion of the letter. In the letter, Mr. Long
expressed respondent's willingness to settle both docketed and
nondocketed cases on the basis of an "at risk settlement" under
section 465. In closing, the letter stated: "This offer to
settle is open until September 28, 1990."
7
Mr. Redding, who was a witness in these cases, was
recused as the Goodwins' counsel of record. See Model Rules of
Professional Conduct rule 3.7.
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