- 2 - taxable years in issue Lone Wolf is subject to the unified audit and litigation procedures of sections 6221 through 62311 enacted by the Tax Equity & Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a), 96 Stat. 648. They further agree that a timely petition was filed and, accordingly, this Court has jurisdiction over this case. The Nirschls, however, argue that they entered into a settlement agreement with respondent which converted their partnership items to nonpartnership items and, with respect to them, ousted this Court's jurisdiction pursuant to sections 6226(d)(1)(A) and 6231(b)(1)(C). The issue is whether the Nirschls and respondent entered into a binding settlement agreement with respect to adjustments relating to the Nirschls' investment in Lone Wolf for the 1983 through 1986 partnership taxable years. FINDINGS OF FACT Lone Wolf is one of a number of partnerships formed to purchase and exploit the rights to certain films. The general partners of those partnerships were Richard M. Greenberg and/or A. Frederick Greenberg.2 Respondent began an examination of the 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. 2 On its partnership returns for the years in issue, Lone Wolf claimed loss deductions based on the alleged purchase of the films "Lone Wolf McQuade" starring Chuck Norris, and "Strange (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011