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GRAPHICS/ACCESS, LTD. v. COMMISSIONER

Docket No. 4298-88.

63 T.C.M. 3148 (1992)

T.C. Memo. 1992-345

H Graphics/Access, Ltd. Partnership, Nelson J. Sapp, Jr., A Partner Other Than The Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed June 15, 1992.

Attorney(s) appearing for the Case

George W. Connelly, Jr., Robert I. White, and Linda S. Paine, 1200 Smith St., Houston, Tex., for the petitioner. Richard T. Cummings and Melanie R. Urban, for the respondent.

Memorandum Opinion

RUWE, Judge:

This case is before the Court on petitioner's motion for an order directing respondent to extend the terms of a settlement agreement to petitioner and other eligible partners pursuant to section 6224(c)(2).1 Section 6224(c) provides in pertinent part:

(c) Settlement Agreement. — In the absence of a showing of fraud, malfeasance, or misrepresentation of fact — (1...

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