Free Stipulation - District Court of Federal Claims - federal

Case 1:05-cv-00785-ECH

Document 47

Filed 11/19/2007

Page 1 of 4

IN TI-IE UNITED S'fATES COURT OF FEDERAL CLAIMS

(into which has been consolidated: No. 05-786 T. No. 05-787 T, No. 05-788 T. No. 05-789 T, No. 05-790 T, No. 05-79 i T, No. 05-792 T)
FFRE HOLDINGS, LLC, by and through Larry D. Russell and Janet M. Russell, as Trustees for the Larry D. Russell and Janet M. Russell Living Trust, a Partner Other Than the Tax Matters Partner,
Plaintift~
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No. 05~ 785 T (Judge Emily C Hevvitt)

THE UNlfED STATES,

Defendant.

STIPULA nON FOR ENTR Y OF JUDGMENT'

COME NOW the plaintiff" and the defendant the United States, to inform the Court of a
settlement of the above-captioned TEFRA parnershi p proceedings, pursuant to RCFC Appendix
F, Rule 7(21), ¡,e, by a stipulation of

the Tax Matters Partner for each partnership, consenting to
judgment set forth belov\!o See RCFC 54(3) and I.R.C. Section

the entry of

the proposed

6224(c). i

i The parties believe that the Court should direct the Clerk of Court to enter a judgment
reciting contents of the proposed judgment described in this stipulation.
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Case 1:05-cv-00785-ECH

Document 47

Filed 11/19/2007

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At issue in the above-captioned çunsolidated cases are Notices of Final Partnership

Administrative Adjustments for the taxable years 1999,2000, and 2001, for three parnerships-FFRE Holdings, LLC; FFRE Acquisitions. LLC; and FFRE Management, LLC. The Tax
:v1atters Partners for FFRE Holdings, LLC, and FFRE Management, LLC. hereby stipulate and

agree on their behalf and on behalf of FfRE Acquisitions, LLC (for which the Tax Matters
Partner is FFRE Management, LLC), to the entry of the t~)iiowing proposed judgment.

PROPOSED JUDGMENT

The adjustments set forth in the Notices of Final Partnership Administrative Adjustment

issued April i 4,2005, to FFRE Holdings, LLC, FFRE Acquisitions, LLC, and FFRE
Management, LLC, for the taxable years i 999,2000, and 2001 are correct except that a
15 percent penalty shall be imposed on the portion of any underpayment attributable to the gross

valuation misstatement as provided by LR.C. Sections 6662(a), 6662(b)(3), 6662(e) and 6662(h).

See l.R.C. Section 6226(0.

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Case 1:05-cv-00785-ECH

Document 47

Filed 11/19/2007

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CONSENT AND CERTIFICA nON

The undersigned Tax Matters Pai1ners for FFRE Holdings, LLC, FFRE Management,

LLC, and FFRE Acquisitions, LLC, by executing this stipulation, consent to the entry of
proposed judgment set forth above and certify that no party objects, nor does any individual
taxpayer affected by this proposed judgment object.
FFRE Management, LLC

FFRE Holdings, LLC

FFRE Acquisitions, LLC

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aid
I

By:'
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lÁ-r
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_cç

BacAl Fhnald
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Bar.' Femald
For FFRE Management, LLC,

Tax .\atters Partnes

Tax rv'ltters Partner

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Case 1:05-cv-00785-ECH

Document 47

Filed 11/19/2007

Page 4 of 4

Respectfully submitted,

,ö \~ \01
Date

(~.c..':~~
BRADLEY A. PATTERSON
Goddard LLP

18500 van Karman Ave., Suite 400 Irvine, California 926 i 2 (949) 253-0500

/1 /;,~I Z- 7
Date

~BERT J. HIG '
Al10rney of Record

~.

Counsel !òr Plaintif

U.S. Deparment of Justice Tax Division Federal Claims Section Court of Post Offce Box 26 Ben Franklin Post Offce Washington, D.C 20044 (202) 307-6580

RICHARD'l MORRISON Acting Assistant Attorney General
DAVID GUSTAFSON
Chief, Cour of Federal Claims Section

1 i 10 h--r~() 1
Date

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Of Counsel

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Attorneys for Defendant

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