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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...)
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