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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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