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into between respondent and investors in the Elektra Hemisphere
tax shelters. Responsibility for providing notice to movants was
with the TMP's of the various Elektra Hemisphere tax shelter
partnerships.
The latest cash settlement agreements that were entered into
between respondent and investors with respect to each of the 1983
Elektra Hemisphere partnership tax years in question and with
respect to the 1984 tax year of the Dillon partnership were
entered into in late 1987 and late 1988 after the respective
FPAA's were mailed to the respective TMP's in early 1987 and early
1988. Any requests by movants herein for consistent settlements
with regard to those specific partnerships and those specific
years should have been made within 60 days after the latest cash
settlement was entered into. Since movants' requests for
consistent settlements pertaining to 1983 and 1984 were made by
movants in 1995, they are untimely by approximately 6 years.
With respect to the 1984 and 1985 tax years of Derringer-1981
and 1982, the latest cash settlement agreements were entered into
in November and December of 1987, before respondent's FPAA's were
mailed to the TMP's in March and April of 1988. Since the
settlements were entered into before the FPAA's were mailed, the
timeliness of movants' requests for consistent settlements is
controlled by section 6224(c)(2), and the requests are untimely
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