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 17

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          because they were not made within the 150-day deadline.  Rather,            
          they were made more than 6 years thereafter.                                
               With regard to Carlton, no cash settlements were entered into          
          during the 1986 through 1988 years or thereafter, and therefore             
          there exists no cash settlement in respect to which any of the              
          movants herein can even seek a consistent settlement.                       
               In spite of the fact that no prior cash settlements exist for          
          some of the Elektra Hemisphere tax shelter partnerships for the             
          years involved herein, some of the movants herein -- who were               
          partners in such partnerships -- argue that they nevertheless               
          should now be entitled to cash settlements for such years.  Such            
          requests for "consistent" settlements are based on cash                     
          settlements that were entered into with partners in partnerships            
          other than partnerships in which movants invested and/or with               
          respect to years other than years in which movants invested.  For           
          example, there were no cash settlements entered into by any                 
          partners in Crowne for 1984, but five of the movants herein are             
          partners in Crowne and are now requesting cash settlements for              
          that year.                                                                  
               Under a plain reading of section 6224(c)(2), "any other                
          partner" is to be interpreted only as a partner in the same                 
          partnership, and "partnership items" relate only to the same                
          partnership tax year.  Partners in different partnerships and               
          partners in the same partnerships for different years do not have           





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