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information that a corruption of the processes of this Court and
of the rights of the taxpayers may have occurred, allegedly as a
result of secret, out-of-the-ordinary settlement agreements
entered into between respondent and certain trial witnesses.
Nothing comparable is presented to us in the instant consolidated
cases.
The credible evidence herein indicates that the settlement
agreements available to investors in the Elektra Hemisphere tax
shelters during 1986 and 1987 were available to all investors. No
credible evidence corroborates movants’ contentions that in 1986
and 1987 they, or their counsel, were not aware of respondent’s
willingness to settle their tax disputes relating to investments
in the Elektra Hemisphere tax shelters on the same cash basis on
which other taxpayers during those years settled with respondent.
Movants' reliance on some ambiguities in certain forms and
letters mailed by respondent to movants regarding terms of
settlements that were available is futile. There is no credible
evidence that such ambiguities were intentional, that they gave
rise to material misrepresentations, or that they in any way
constituted fraud or malfeasance.
There is no evidence herein that would support a finding of
fraud, malfeasance, or misrepresentations of fact on respondent's
behalf with regard to any aspect of the cash settlements that were
entered into during 1986 through 1988 between respondent and other
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