Thomas J. Fisher and Ann M. Fisher, et al. - Page 4




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          petitioners’ motion for entry of decision.  In docket Nos. 5879-            
          89, 25436-90, and 1321-92, we shall grant respondent’s motions              
          for entry of decisions, and we shall deny the motions for entry             
          of decisions filed by petitioners as participating partners.                

                                     Background                                       
               At the time the petitions were filed, petitioners resided in           
          and the relevant partnerships maintained their offices in New               
          York State.                                                                 
               On their Federal income tax returns for the years 1980                 
          through 1985, petitioners claimed loss deductions relating to               
          their limited partnership investments in White Rim and Syn-Fuel             
          as follows:                                                                 

                      Claimed Loss Deductions                                         
      Partnership     1980      1981      1982      1983      1984   1985             
      White Rim $39,925 $45,479 $50,880 $13,665   ---   ---                           
      Syn-Fuel        ---       40,392    38,319    40,890    $33,414   $6,927        

               Respondent disallowed the above-claimed loss deductions                
          relating to petitioners’ investments in the White Rim and Syn-              
          Fuel partnerships for the tax years 1980 through 1982 and the               
          partnerships’ loss deductions for 1983 through 1985.                        
               At a Court hearing on April 22, 1986, respondent’s counsel             
          announced that respondent would accept settlement offers from               
          investors in the White Rim and related limited partnerships on              






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