Vulcan Oil Tech. Partners v. Commissioner
United States Tax Court
Movants were investors in the so-called Elektra Hemisphere tax shelters. Among other things, movants' motions seek from the Court orders -- (1) under the TEFRA partnership provisions and under Rule 245(b) that would grant movants leave to file untimely notices of election to participate in the instant consolidated TEFRA partnership proceedings with attached notices of election to participate; (2) under Rule 50 that would set aside settlement agreements that were entered into…
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Movants were investors in the so-called Elektra Hemisphere tax shelters. Among other things, movants' motions seek from the Court orders -- (1) under the TEFRA partnership provisions and under Rule 245(b) that would grant movants leave to file untimely notices of election to participate in the instant consolidated TEFRA partnership proceedings with attached notices of election to participate; (2) under Rule 50 that would set aside settlement agreements that were entered into by most of the movants herein during 1994 and later years; and (3) under the TEFRA partnership provisions that would…
1Opinion of the Court
OPINION
Swift, Judge:
This matter is before the Court in these consolidated cases on movants’ motions, under the Tax Equity and Fiscal Responsibility Act of 1982 (tefra), Pub. L. 97-248, 96 Stat. 324, partnership provisions and under Rule 245(b),2 for leave to file untimely notices of election to participate with attached notices of election to participate, and motions, under Rule 50, to set aside settlement agreements and/or to require respondent now to enter into consistent settlement agreements. An evidentiary hearing was held on May 21, 1997, in regard to these motions.
The particular years…
2Cases cited8 opinions
- United States v. CaceresSupreme Court of the United States · 1979
- Krause v. CommissionerUnited States Tax Court · 1992
- Hildebrand v. CommissionerCourt of Appeals for the Tenth Circuit · 1994
- Conrad Keado v. United States of America, Conrad L. Keado and Linda W. Keado v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- United States v. Herbert L. HorneCourt of Appeals for the First Circuit · 1983
3 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Greenberg Bros. P'ship 4 v. CommissionerUnited States Tax Court · 1998
- McGann v. United StatesUnited States Court of Federal Claims · 2007
- Estate of Campion v. CommissionerUnited States Tax Court · 1998
- Bush v. United StatesCourt of Appeals for the Federal Circuit · 2013
- McGann v. United StatesUnited States Court of Federal Claims · 2008
14 more not listed; retrieve them via the Exa API.