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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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