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NOTES 201 Tax Lawyer, Vol. 54, No. 1 NOTE UNDER TEFRA PROCEDURES, PARTNERS CANNOT CHANGE THEIR ELECTION FROM LITIGATION TO A CONSISTENT SETTLEMENT: PROCHORENKO V. UNITED STATES In Prochorenko v. United States,1 on cross motions for summary judgment, the Court of Federal Claims addressed the scope of the settlement provision of the Tax Equity and Fiscal Responsibility Act of 1982 (“TEFRA”)2 in determiniin a potential reduction of partnership tax liability.3 The court determined that, when a...