Legal Opinion

Estate of Campion v. Commissioner

United States Tax Court

Decided March 5, 1998No. Tax Ct. Dkt. No. 12235-86. Docket Nos. 22346-86, 31310-86, 32931-86, 4142-87, 12476-87, 18986-87, 21147-87, 24227-87, 24013-88, 4646-89, 7300-89, 8272-89, 18502-89PublishedCited by 12 opinions

Petitioners (investors in the so-called Elektra Hemisphere tax shelters) move for leave to file motions under Rule 162 to vacate final decisions that have been entered herein and to require respondent now to enter into revised settlement agreements with petitioners (that reflect settlement terms available from respondent to investors in 1986, 1987, and 1988) Held: Petitioners' motions are denied.

1Opinion of the Court

OPINION

Swift, Judge:

This matter is before the Court in these consolidated cases on petitioners’ motions for leave to file motions to vacate decisions with attached motions to vacate under Rule 162.

Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure, and all section references are to the Internal Revenue Code for the years in issue.

In each of these cases, petitioners and respondent settled all issues, and final decisions have been entered. The 90-day appeal period has expired, and petitioners now seek orders from the Court vacating the decisions…

2Cases cited13 opinions

  1. In Re Coordinated Pretrial Proceedings in Antibiotic Antitrust Actions. Pfizer, Inc. v. International Rectifier Corp.Court of Appeals for the Eighth Circuit · 1976
  2. Ben Abatti and Margaret Abatti v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
  3. Davis v. CommissionerUnited States Tax Court · 1976
  4. William H. Kenner and Eleanor v. Kenner v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1968
  5. Krause v. CommissionerUnited States Tax Court · 1992

8 more not listed; retrieve them via the Exa API.

3Cited by12 opinions

  1. Vulcan Oil Tech. Partners v. CommissionerUnited States Tax Court · 1998
  2. Harrison v. CommissionerUnited States Tax Court · 2012
  3. Stroube v. Comm'rUnited States Tax Court · 2008
  4. Elghanian v. Comm'rUnited States Tax Court · 2005
  5. Stewart v. Comm'rUnited States Tax Court · 2005

7 more not listed; retrieve them via the Exa API.

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