- 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).
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