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or, alternatively, for entry of decisions reflecting terms of
prior settlements.3
The issues are as follows: (1) Whether, under the
circumstances, participants are entitled to consistent settlement
terms pursuant to section 6224(c)(2); and (2) whether section
301.6224(c)-3T(b), Temporary Proced. & Admin. Regs., 52 Fed. Reg.
6787 (Mar. 5, 1987), is valid.
The relevant facts are not in dispute and may be summarized
as follows. The partnerships involved in these cases were formed
to purchase and exploit the rights to certain films.4 The
general partners of these partnerships were Richard M. Greenberg
and/or A. Frederick Greenberg. Respondent began an examination
3
A list of the participants is attached to this opinion
in an Appendix.
4
On the partnerships' respective returns for the years
in issue, the partnerships claimed loss deductions based upon the
alleged purchase of various first-run motion pictures. The films
represent a roster of the famous and forgotten from 1980's
cinema. The partnerships and their underlying films include,
inter alia, the following: Greenberg Brothers Partnership #4,
a.k.a. Breathless Associates (the 1983 remake of "Breathless"
starring Richard Gere); Greenberg Partnership #12, a.k.a. Lone
Wolf McQuade Associates ("Lone Wolf McQuade" starring Chuck
Norris); Easy Money Associates (Rodney Dangerfield and Joe Pesci
starring in "Easy Money"); Cinema '84 (James Cameron directing
Arnold Schwarzenegger in "The Terminator", horror genre entries
"The Howling II" and "Return of the Living Dead"); First Blood
Associates ("First Blood" the initial entry in Sylvester
Stallone's "Rambo" series); Under Fire Associates (Nick Nolte and
Gene Hackman starring in "Under Fire"); and Cinema '85
("Salvador" directed by Oliver Stone and starring James Woods and
James Belushi and "At Close Range" starring Sean Penn and
Christopher Walken).
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