- 5 -
through 6223 (enacted as part of the Tax Equity & Fiscal
Responsibility Act of 1982, Pub. L. 97-248, sec. 402(a), 96 Stat.
648). Id.
On December 18, 1995, respondent issued Forms 870-P(AD),
Settlement Agreement for Partnership Adjustments, covering tax
years 1985 and 1986, to at least two Partnership investors. The
proffered settlement packages proposed a diminution of the
partners’ allocable deficiencies in the amount of one-half of
their respective cash contributions, as well as the elimination
of all applicable penalties; interest charges were to be
expressly preserved. Petitioners were not informed of the
settlement offers extended at that time or of the prior
litigation.
On March 5, 1996, respondent issued notices of final
partnership administrative adjustment (FPAA) for 1985 and 1986 to
Claude B. Amarnick, reasserting respondent’s determination that
the Partnership was orchestrated as a tax shelter contrivance,
and disallowing all losses and deductions. The Estate of Mr.
Amarnick (in its capacity as a partner other than the tax matters
partner (TMP)) petitioned for readjustment of the partnership
items. William A. Tauskey, Sr., in concert with several other
partners also in receipt of the FPAA notices, intervened in the
proceeding on October 3, 1996. Prior to his death during the
pendency of the TEFRA litigation, Mr. Tauskey was serving as the
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