Greenberg Brothers Partnership #12, a.k.a. Lone Wolf McQuade Associates, and Richard M. Greenberg, Tax Matters Partner - Page 13

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          that the Nirschls never executed either, and, consequently, there           
          was no settlement of their case.8                                           
               To reflect the foregoing,                                              
                                             An appropriate order will be             
                                        issued denying the Nirschls'                  
                                        motion to dismiss for lack of                 
                                        jurisdiction.                                 

























               8                                                                      
                    We leave for a subsequent opinion the question whether            
          the Nirschls may be entitled to consistent settlement terms                 
          pursuant to sec. 6224(c)(2) and sec. 301.6224(c)-3T, Temporary              
          Proced. & Admin. Regs., 52 Fed. Reg. 6787 (Mar. 5, 1987).                   

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