Joseph and Theresa Momot - Page 6

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          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 notice              









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