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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, 96
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