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Karlsson v. Commissioner, T.C. Memo. 1997-432; and Vanderschraaf
v. Commissioner, T.C. Memo. 1997-306.
In Acierno v. Commissioner, supra, we found that the Denver-
based partnerships that are involved in the instant cases were
similar to the Manhattan and Wichita partnerships that were
involved in the lead test cases in the Elektra Hemisphere tax
shelter project of Krause v. Commissioner, supra, and accordingly
that the limited partners of the Denver-based partnerships who had
not settled their cases with respondent were to be bound by the
opinion in Krause. The settlements that most of the movants
herein entered into, during 1994 and later years, are consistent
with our decisions in Krause and the above-cited related cases
(namely, no deductions are to be allowed to the taxpayers relating
to their investments in the Elektra Hemisphere tax shelters, and
the taxpayers are not to be held liable for additions to tax or
penalties other than increased interest under section 6621(c) or
its predecessor section 6621(d)) (hereinafter referred to as the
no-cash settlements).
On an untimely basis, the majority of the movants herein now
seek permission from the Court to file notices of election to
participate in the instant TEFRA partnership proceedings for the
purpose of seeking an order from the Court that would set aside
the no-cash settlement agreements that they entered into and that
would require respondent to enter into revised settlement
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