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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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Last modified: May 25, 2011