Vulcan Oil Technology Partners, Vanguard Oil Technology Partners, Drake Oil Technology Partners, Dillon Oil Technology Partners, Derringer Oil Technology Partners-1981, Derringer Oil Technology - Page 5

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          agreements with movants consistent with the more favorable                  
          settlement terms that were available generally to investors in the          
          Elektra Hemisphere tax shelters during 1986, 1987, and 1988                 
          (namely, tax deductions were allowed for the amount of cash that            
          investors had invested in the Elektra Hemisphere tax shelters and           
          no additions to tax or penalties were imposed other than increased          
          interest under section 6621(c) or its predecessor section 6621(d)           
          (hereinafter referred to as the cash settlements).                          
               The remaining movants herein have not yet entered into any             
          settlement agreements with respondent relating to tax benefits              
          movants claimed on their Federal income tax returns relating to             
          their Elektra Hemisphere tax shelter investments.  Such movants             
          seek from the Court an order that would require respondent to now           
          enter into settlement agreements with them consistent with the              
          cash settlements that were available generally to investors in the          
          Elektra Hemisphere tax shelters during 1986, 1987, and 1988.                
               All of the movants herein seek permission from the Court to            
          file notices of election to participate in the instant TEFRA                
          partnership proceedings solely for purposes of obtaining from the           
          Court an order requiring respondent to enter into settlements with          
          them consistent with the terms of the cash settlements.                     
               Beginning in 1986, respondent’s settlement position with               
          regard to investments in the Elektra Hemisphere tax shelters                
          reflected the cash settlement terms to which many investors,                





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