John S. Halpern - Page 3




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          the investment tax credit and $424,106 of property qualifying for              
          the business energy credit, partially resulting in a $43,722                   
          claimed regular investment tax credit and resulting in a $42,411               
          claimed business energy investment credit with respect to RRA.                 
          Petitioner invested $50,000 in RRA.                                            
               By letter dated February 19, 1988, respondent proposed to                 
          disallow the deductions from RRA and Greenfield and the credits                
          from RRA.  Petitioner was represented by the law firm of Kirkland              
          & Ellis with respect to the Greenfield issues.  By letter dated                
          March 30, 1988, Kirkland & Ellis asked that the RRA issues be                  
          deferred until the Greenfield issues are resolved.  On September               
          6, 1990, respondent’s Appeals Office executed a closing agreement              
          with respect to the Greenfield issues.  That agreement was signed              
          by Steven Kamerman (Mr. Kamerman) on behalf of petitioner.                     
               With regard to RRA, on August 2, 1990, Mr. Kamerman and                   
          petitioner executed a closing agreement.  That agreement was                   
          signed by respondent’s Appeals Office on September 6, 1990.  The               
          agreement provided, inter alia:                                                
                    (1) The taxpayer [petitioner] has claimed income,                    
               deductions, and/or credits on his tax returns for the                     
               taxable years 1981 and 1982 relating to the Resource                      
               Reclamation Assoc. tax shelter (hereafter the TAX SHELTER)                
               which are in dispute between the taxpayer and the                         
               Commissioner of Internal Revenue (hereafter the IRS).                     
                    (2) Items of income, deductions, and/or credits                      
               relating to the TAX SHELTER are in issue in a case pending                
               before the United States Tax Court Harold M. Provizer and                 
               Joan Provizer v. Commissioner, Docket No. 27141-86                        
               (hereafter the CONTROLLING CASE).                                         





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