Legal Opinion

Greenberg Bros. P'ship 4 v. Commissioner

United States Tax Court

Decided August 24, 1998No. Tax Ct. Dkt. No. 19575-91. Docket Nos. 22780-91, 29878-91, 621-92, 623-92, 3968-92, 4432-92, 13014-92, 15641-92, 12062-94Published

Pursuant to sec. 6224(c)(2), I.R.C., Ps request consistent settlement terms of partnership items with earlier settlement agreements that include concessions pertaining to partnership and nonpartnership items. HELD: A settlement agreement that includes concessions of partnership and nonpartnership items is not subject to the consistent settlement provisions under sec. 301.6224(c)-3T, Temporary Proced. & Admin. Regs., 52 Fed.

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Pursuant to sec. 6224(c)(2), I.R.C., Ps request consistent settlement terms of partnership items with earlier settlement agreements that include concessions pertaining to partnership and nonpartnership items. HELD: A settlement agreement that includes concessions of partnership and nonpartnership items is not subject to the consistent settlement provisions under sec. 301.6224(c)-3T, Temporary Proced. & Admin. Regs., 52 Fed. Reg. 6787 (Mar. 5, 1987). HELD, FURTHER: Sec. 301.6224(c)-3T, Temporary Proced. & Admin. Regs., supra, is valid.

1Opinion of the Court

GREENBERG BROTHERS PARTNERSHIP #4, a.k.a. BREATHLESS ASSOCIATES, RICHARD M. GREENBERG, TAX MATTERS PARTNER, ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent. GREENBERG BROTHERS PARTNERSHIP #4, a.k.a. BREATHLESS ASSOCIATES, RICHARD M. GREENBERG, TAX MATTERS PARTNER, ET AL., 1 Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Greenberg Bros. P'ship #4 v. Commissioner

Tax Ct. Dkt. No. 19575-91. Docket Nos. 22780-91, 29878-91, 621-92, 623-92, 3968-92, 4432-92, 13014-92, 15641-92, 12062-94

United States Tax Court

111 T.C. 198; 1998 U.S. Tax Ct. LEXIS 42; 111 T.C. No. 7;

August…

2Cases cited37 opinions

  1. Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
  2. United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
  3. United States v. American Trucking AssociationsSupreme Court of the United States · 1940
  4. Morton v. RuizSupreme Court of the United States · 1974
  5. Burlington Northern Railroad v. Oklahoma Tax CommissionSupreme Court of the United States · 1987

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