Greenberg Brothers Partnership #12, a.k.a. Lone Wolf McQuade Associates, and Richard M. Greenberg, Tax Matters Partner - Page 3

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          partnership at some point in the mid-1980's as part of a national           
          project focusing on the various partnerships of the Greenberg               
          Brothers (the Greenberg Brothers project).  Richard M. Greenberg,           
          who was then the tax matters partner (TMP) of Lone Wolf, retained           
          attorney Peter L. Faber (Mr. Faber) to represent the partners at            
          the partnership level during respondent's examination.3  Mr.                
          Faber also represented the partners at the partnership level upon           
          filing the petition in this case.                                           
               The Nirschls were limited partners in Lone Wolf during the             
          partnership taxable years in issue.  The Nirschls have elected to           
          participate in these proceedings pursuant to section 6226(c)(2)             
          and Rule 245(b).                                                            
               Joseph F. Long (Mr. Long), an attorney in respondent's                 
          District Counsel office in Hartford, Connecticut, represented               
          respondent in the settlement negotiations for the Greenberg                 
          Brothers project.  After Mr. Long was assigned to the project, he           
          and Mr. Faber discussed the possibility of settling the Greenberg           
          Brothers partnership cases by a settlement at the partnership               
          level.                                                                      

               2(...continued)                                                        
          Invaders".                                                                  
               3                                                                      
                    Richard M. Greenberg became disqualified from acting as           
          the TMP when an involuntary petition in bankruptcy was filed                
          against him in January 1994.  See sec. 6231(c); sec.                        
          301.6231(a)(7)-1(l)(1)(iv), Proced. & Admin. Regs.; sec.                    
          301.6231(c)-7T, Temporary Proced. & Admin. Regs., 52 Fed. Reg.              
          6793 (Mar. 5, 1987).                                                        




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