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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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