- 10 -
1984 Derringer-1981 4/11/88 11/17/87
Derringer-1982 3/28/88 12/08/87
Dillon 4/11/88 11/15/88
1985 Derringer-1981 4/11/88 9/17/87
Derringer-1982 3/28/88 12/08/87
As settlement agreements were finalized, personnel in
respondent's Ogden Service Center, which was the key-case Service
Center for the Denver-based Elektra Hemisphere tax shelter
partnerships, generally mailed copies of the final agreements to
the tax matters partner of each partnership.
In late 1993 and early 1994, respondent mailed settlement
offers to investors in the Denver-based partnerships who had not
previously settled, reflecting respondent's then-current no-cash
settlement position. The mailing from respondent contained a
standard transmittal letter, a schedule of partnership adjustments
consistent with this Court's opinion in Krause v. Commissioner, 99
T.C. 132 (1992), and a proposed settlement agreement form.
Respondent's transmittal letters contained a statement that
"we have completed settlement negotiations for the partnership
shown above," and indicated a 30-day deadline for acceptance of
the terms of the settlement.
All of the movants in these cases with respect to the instant
motions (except Frank Acierno, Jack and Katherine Schoellerman,
Mary F. Hill, and David and Barbara Jonson) executed settlement
agreements reflecting the no-cash settlement terms consistent with
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011