First Blood Associates, Richard M. Greenberg, Tax Matters Partner, et al. - Page 5

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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."                                   

                    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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