- 3 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011