- 6 - Partnership’s TMP, pursuant to respondent’s appointment under section 6231(a)(7). Neither Mr. Tauskey nor respondent furnished a copy of the FPAAs or otherwise provided notice of the partnership action to petitioners. The partnership action was settled on April 25, 2000. The settlement, predicated on the stipulation of the partnership transactions as being devoid of economic substance and a bona fide profit motive, partially disallowed the partnership loss and deduction items for 1985, and denied the entirety of the partnership losses and deductions for 1986. The TMP, James A. Grever (appointed to succeed the deceased Mr. Tauskey) was an individual investor, unaffiliated with the Partnership’s originator or managerial agents, and, therefore, could not ascertain the identities of the remaining partners not participating in the partnership action. Respondent compiled a schedule of the known nonparticipating partners, which included petitioners and their contact information. On October 20, 2000, the Court granted Mr. Grever’s motion for an order directing service of any notice of settlement on the aforementioned nonparticipating partners, and providing Mr. Grever contingent relief from any liability otherwise occasioned by his relying solely on respondent’s schedule in the discharge of the noticePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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