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Stat. 324, partnership provisions and under Rule 245(b),2 for
leave to file untimely notices of election to participate with
attached notices of election to participate, and motions, under
Rule 50, to set aside settlement agreements and/or to require
respondent now to enter into consistent settlement agreements. An
evidentiary hearing was held on May 21, 1997, in regard to these
motions.
The particular years before us in these consolidated cases
are 1983, 1984, and 1985 -- years subject to the TEFRA partnership
provisions. In Estate of Campion v. Commissioner, 110 T.C. __
(1998), with regard to years prior to the effective date of the
TEFRA partnership provisions, other investors in the Elektra
Hemisphere tax shelters have filed motions similar to the instant
motions. Our opinion in Campion is also filed this date.
The underlying tax shelter investments that are involved in
these consolidated cases constitute investments in seven Denver-
based limited partnerships and are related to the so-called
Elektra Hemisphere tax shelter investments that were the subject
of litigation in this Court in Krause v. Commissioner, 99 T.C. 132
(1992), affd. sub nom. Hildebrand v. Commissioner, 28 F.3d 1024
(10th Cir. 1994); Acierno v. Commissioner, T.C. Memo. 1997-441;
2 Unless otherwise indicated, all Rule references are to the
Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code for the years in
issue.
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