Ralph Tashjian - Page 2

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               (1) Whether petitioner’s arguments that                                
          (a) Synergistics/Blueprint Software (Synergistics), Lumenetics,             
          and Data Flex partnerships were not properly subjected to the               
          unified audit and litigation procedures of sections 6221 through            
          6234 (hereinafter referred to as TEFRA procedures), for taxable             
          years 1982, 1983, and 1984, and (b) Dennis R. DiRicco (DiRicco)             
          was ineligible to serve as tax matters partner (TMP) of the                 
          partnerships may be considered in this case;                                
               (2) if so, whether respondent’s Appeals officer properly               
          determined, during the section 6330 hearing (hearing), that                 
          petitioner was precluded by section 6330(c)(2)(B) from                      
          challenging the use of TEFRA audit procedures in the previous               
               (3) whether respondent’s criminal investigation of                     
          petitioner converted the partnership items on his tax returns to            
          nonpartnership items in 1982, 1983, and 1984;                               
               (4) whether petitioner was denied due process by being                 
          unable to access records allegedly held by respondent; and,                 
               (5) whether there was an abuse of discretion by the Appeals            
          officer of the Internal Revenue Service (IRS) in determining that           
          collection of petitioner’s unpaid income tax liabilities for                
          1982, 1983, and 1984 should proceed.                                        

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