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of the partnerships at some point in the mid-1980's as part of a
national project focusing on the various partnerships of the
Greenberg Brothers.
The schedule below sets forth the specific dates on which
respondent issued notices of final partnership administrative
adjustments (FPAA's) determining adjustments to partnership items
for each of the partnerships:
Partnership Petition
Partnership Docket No. Taxable Years FPAA DateDate
Greenberg #4/Breathless 19575-911983-87 June 3, 1991 Aug. 30, 1991
Greenberg #12/Lone Wolf 22780-911983-86 July 8, 1991 Oct. 7, 1991
Easy Money Associates29878-91 1983-86 Oct. 7, 1991 Dec. 20, 1991
Cinema '84 621-92 1984-89 Oct. 15, 1991 Jan. 8, 1992
First Blood Associates 623-921983-87 Oct. 21, 1991 Jan. 8, 1992
Under Fire Associates 3968-921983-86 Dec. 9, 1991 Feb. 24, 1992
Cinema '85 4432-92 1985-89 Dec. 2, 1991 Feb. 28, 1992
First Blood Associates 13014-921988 Mar. 24, 1992 June 12, 1992
First Blood Associates 15641-921989 Apr. 20, 1992 July 10, 1992
First Blood Associates 12062-941990 Mar. 14, 1994 July 11, 1994
It is undisputed that the petitions were timely filed and
the requests for consistent settlement terms were timely made in
these cases. With the exception of docket No. 12062-94, at the
time the petitions were filed in these cases, each partnership's
principal place of business was located at Greenwich,
Connecticut. At the time the petition was filed in docket No.
12062-94, that partnership was in dissolution; the partnership's
principal place of business during its winddown period was
located in New York, New York.
Each of the settlement agreements with which participants
seek consistent settlement was entered into and effective on
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