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 14

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          notification to the Court, only applies to settlements with                 
          participating partners, and the evidence does not establish that            
          any of the participating partners in the instant cases ever                 
          entered into prior cash settlements with respondent.  Also, Rule            
          248(c)(2), which requires respondent to give notice to the TMP's            
          when a partner enters into a settlement, was not effective until            
          September 1, 1988, see Note to Rule 248(c)(2), 90 T.C. 1376                 
          (1988), and there is no credible evidence that respondent failed            
          to comply with Rule 248(c)(2) after that date.                              
               For the period January 19, 1984, through September 1, 1989, a          
          provision of respondent’s manual provided that upon receipt of a            
          settlement in a TEFRA partnership audit or proceeding,                      
          respondent’s Service Center was to notify the appropriate TMP’s of          
          the settlement, and the responsibility then fell on the TMP’s to            
          notify other partners of the settlement.  Movants argue that                
          respondent did not follow this manual procedure with regard to the          
          Elektra Hemisphere tax shelter partnerships, and therefore that             
          all movants herein (those who already entered into no-cash                  
          settlements and those who have not yet entered into any                     
          settlements) should now be entitled to enter into cash                      
          settlements.  With regard to this argument, we note that movants            
          have failed to present any credible testimony from the TMP's of             
          the partnerships, from other partners, from their representatives,          
          or others to support their claim that respondent failed to give             





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