Crop Associates - Page 1

                                   113 T.C. No. 15                                    

                               UNITED STATES TAX COURT                                

              CROP ASSOCIATES - 1986, W. KEITH OEHLSCHLAGER, A PARTNER                
                  OTHER THAN THE TAX MATTERS PARTNER, Petitioner v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 12532-90.               Filed September 14, 1999.           

                    The tax matters partner, intervenor, has moved to                 
               file amendment to petition, which would add to the                     
               petition the affirmative defense of equitable                          
               recoupment.  R objects on various grounds.  We agree                   
               with R that equitable recoupment is not a partnership                  
               item and that granting the motion would suprise and                    
               substantially disadvantage R.  The motion will be                      
                    Held:  Equitable recoupment is not a partnership                  
               item; held, further, R would be surprised and                          
               substantially disadvantaged were we to grant the                       

               Steven R. Mather, for intervenor.                                      
               William H. Quealy and Alice M. Harbutte, for respondent.               

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