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please advise us * * *. We will then arrange for the appropriate
documents to be sent to you."
By letter dated November 30, 1993, Mr. Noumair wrote to Mr.
Long with regard to partners in Lone Wolf and seven other
Greenberg Brothers partnerships who desired "to accept the IRS
settlement offer and opt out of the TEFRA proceeding". The
letter also stated: "I would appreciate it if, with respect to
the partners who wish to opt out, you would send to me the
documents you will require to be executed for filing in the Tax
Court." Attached to the letter was a separate list for each
partnership, indicating the names and interests of the partners
wishing to opt out of the TEFRA proceeding; the Nirschls are
listed on an attachment titled "Limited Partners in Lone Wolf
McQuade Associates Who Want to Opt Out and Settle as of
11/30/93". According to Mr. Long, at that time, settlement would
be "achieved" by signing a Form 870 or entering into a closing
agreement. Mr. Faber also had understood "that there would be
some documents that would have to be executed to implement * * *
[a settlement]." The Nirschls never executed either a Form 870
or a closing agreement.
OPINION
The Tax Court is a Court of limited jurisdiction and may
exercise jurisdiction only to the extent expressly permitted by
statute. See sec. 7442; Trost v. Commissioner, 95 T.C. 560, 565
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