- 3 - partnerships), affd. sub nom. Ferguson v. Commissioner, 29 F.3d 98 (2d Cir. 1994); Krause v. Commissioner, 99 T.C. 132 (1992), (relating to the White Rim partnerships), affd. sub nom. Hildebrand v. Commissioner, 28 F.3d 1024 (10th Cir. 1994).3 The instant motions focus primarily on whether petitioners should be treated as having entered into binding settlement agreements of the taxes and penalties pertaining to their investments in the White Rim and Syn-Fuel partnerships on a basis more favorable than that available to other partners in the same partnerships. Petitioners’ counsel complains vigorously of respondent’s general handling of the above tax shelters and of respondent’s particular treatment of petitioners. Whatever may be the explanation for petitioners’ financial and other problems relating to their investments in the above partnerships, the evidence herein does not establish that petitioners entered into binding settlement agreements with respondent of their tax liabilities, additions to tax, and increased interest in a manner inconsistent with respondent’s proposed decisions. For the reasons set forth below, in docket No. 27394-86, we shall deny 3 For other opinions relating to the White Rim partnerships, see Hill v. Commissioner, 204 F.3d 1214 (9th Cir. 2000); Copeland v. Commissioner, T.C. Memo. 2000-181; Marinovich v. Commissioner, T.C. Memo. 1999-179; Acierno v. Commissioner, T.C. Memo. 1997- 441, affd. without published opinion 185 F.3d 861 (3d Cir. 1999); Karlsson v. Commissioner, T.C. Memo. 1997-432; Vanderschraaf v. Commissioner, T.C. Memo. 1997-306, affd. without published opinion 211 F.3d 1276 (9th Cir. 2000).Page: Previous 1 2 3 4 5 6 7 8 9 Next
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