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notice of final partnership administrative adjustment (FPAA) with
respect to its 1983 and 1984 years. On September 4, 1990,
respondent issued an FPAA to Asher with respect to each of
Wilshire’s 1983 and 1984 years. On October 26, 1990, Wilshire
filed a petition with this Court with respect to its FPAA.
In May 1991, Moira Sullivan (Ms. Sullivan), an IRS attorney,
was assigned to work on the Swanton programs. In September 1991,
Ms. Sullivan and counsel representing the TEFRA Swanton programs
reached a basis of settlement. Negotiations regarding the terms
of this settlement continued until September 1993. The final
terms of settlement allowed the investors to deduct half their
cash investments, and subjected them to increased interest under
section 6621(c). In addition, the settlement required the
consent of all the Wilshire investors. One Wilshire investor
refused to consent to the settlement, and, eventually, separate
closing agreements were prepared for each Wilshire partner.
Trials for the pre-TEFRA Swanton programs began in the Tax
Court in 1989 and were completed in late 1992. Smith v.
Commissioner, 92 T.C. 1349 (1989); Kelley v. Commissioner, T.C.
Memo. 1993-495. Respondent filed his final brief in the pre-
TEFRA Tax Court litigation on August 14, 1992.5 Respondent
5 The Tax Court docket entry sheet for Kelley v.
Commissioner, supra, docket No. 34982-85, shows this date.
Respondent filed a notice of intent not to file a surrebuttal
brief on Sept. 30, 1992.
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