Greenberg Brothers Partnership #4, a.k.a. Breathless Associates, Richard M. Greenberg, Tax Matters Partner, et al. - Page 3

                                        - 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