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Encoder Associates (Encoder), a limited partnership. Encoder was
part of a national group of about 83 energy management systems
limited partnerships (EMS). Respondent audited the EMS
partnerships from 1979 to 1985. Encoder and some of the other
EMS partnerships were subject to the unified partnership audit
and litigation provisions of the Tax Equity and Fiscal
Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a),
96 Stat. 324, 648.
EMS taxpayers filed about 1,200 petitions in the Tax Court.
In 1987, an EMS shelter group was formed, and the participants
agreed to have trials in and to be bound by the results of two
EMS test cases.
On October 14, 1987, attorneys from both sides met to plan
an Appeals conference for all Encoder limited partners. The
Appeals conference for all Encoder limited partners was held on
November 10, 1987.
Around 1989, respondent had settlement negotiations with
Encoder. Some of Encoder's limited partners settled, but
Signature did not. On June 4, 1990, respondent sent a final
partnership administrative adjustment (FPAA) to Signature telling
Signature about adjustments to Encoder's 1982 return.
The test cases were tried in May 1991. Decisions in the
test cases became final on September 2, 1993. Decision documents
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Last modified: May 25, 2011