Crop Associates-1986, Frederick H. Behrens, Tax Matters Partner - Page 9




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               On August 3, 1995, based on the information that a basis of            
          settlement had been reached, we again continued the trial of this           
          case.                                                                       
               Settlement discussions and related procedures continued                
          until the expiration, on February 11, 1999, of the period                   
          provided for in section 6224(c)(2) for partners to demand                   
          consistent settlement agreements from respondent.  Respondent               
          entered into consistent settlement agreements with some, but not            
          all, of the limited partners.  Petitioner did not enter into a              
          settlement agreement.                                                       
               On February 2, 1998, respondent and the participating                  
          partners who remained active in the case (the remaining                     
          participating partners) jointly moved to withdraw certain motions           
          and documents previously filed in this case (the motion to                  
          withdraw), including the 1995 misconduct motion.  The motion to             
          withdraw was granted on September 2, 1998.                                  
               On October 29, 1998, we allowed counsel for the remaining              
          participating partners to withdraw from the case.                           
               On June 4, 1999, we set this case for trial at a special               
          session scheduled to commence on October 4, 1999 (the October 4             
          special trial session).                                                     
               On July 2, 1999, petitioner made the misconduct motion (the            
          motion).  We set the motion for an evidentiary hearing (the                 
          hearing) at the October 4, 1999, special trial session.  The                






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