- 17 - 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 havePage: 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