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 11

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          the Krause opinion and such settlements were finalized.  The                
          earliest settlement agreement executed by a movant herein was               
          signed on January 3, 1994, and the latest one was signed on                 
          December 1, 1994.                                                           
               Between February 16 and March 27, 1995, written requests to            
          respondent were made by the movants herein (with exception of               
          William and Arlene Ginn and Lomand and Janice Beals)4 for the               
          opportunity to set aside their prior no-cash settlement agreements          
          with respondent and to enter into new settlement agreements with            
          respondent consistent with the cash settlement terms that had been          
          entered into by other investors during 1986, 1987, and 1988.                
          Respondent denied each such request on the grounds that each                
          request was untimely, that each investor making such request had            
          previously entered into a settlement agreement with respondent,             
          and that each such settlement agreement had converted the                   
          investors' partnership items to nonpartnership items.                       
               The TEFRA provisions expressly provide that where a                    
          settlement agreement is entered into between respondent and a               
          partner in a partnership before issuance of the relevant FPAA to            
          the tax matters partner (TMP), other partners who wish to enter             
          into consistent settlement agreements must make requests therefor           
          within 150 days after the FPAA is mailed to the TMP.  Section               


          4    The Ginns and the Beals appear not to have made a written              
          request to respondent for a consistent settlement.                          




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