- 2 - Movants were investors in the so-called Elektra Hemisphere tax shelters. Among other things, movants' motions seek from the Court orders -- (1) under the TEFRA partnership provisions and under Rule 245(b) that would grant movants leave to file untimely notices of election to participate in the instant consolidated TEFRA partnership proceedings with attached notices of election to participate; (2) under Rule 50 that would set aside settlement agreements that were entered into by most of the movants herein during 1994 and later years; and (3) under the TEFRA partnership provisions that would require respondent now to enter into settlement agreements with movants consistent with settlement terms that were available to investors in the Elektra Hemisphere tax shelters during 1986, 1987, and 1988. Held: Movants' motions are denied. Declan J. O'Donnell, for movants. Marilyn S. Ames and Dennis M. Kelly, for respondent. OPINION SWIFT, Judge: This matter is before the Court in these consolidated cases on movants' motions, under the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, 96Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011