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Argued: January 18, 2002

In this consolidated appeal of three consolidated tax cases, petitioners-appellants and appellant appeal from orders entered by the United States Tax Court in favor of respondent-appellee Commissioner of Internal Revenue (the “Commissioner”). See First Blood Assocs. v. Comm’r, No. 00-4267 (Tax Court Docket Nos. 623-92, 13014-92, 12062-94, 15641-92); Greenberg Bros. P’ship No. 12 v. Comm’r, No. 00-4265 (Tax Court Docket No. 22780-91); Cinema ’84 v. Comm’r, No. 00-4263 (Tax Court Docket No. 621-92). We granted the parties’ joint motion to consolidate the three consolidated tax cases into one appeal, because the cases concern the tax treatment of a set of partnerships with overlapping issues and similar factual background.

These cases arise from the Commissioner’s investigation of certain related partnerships formed to market a number of motion picture films. There are three distinct issues on appeal. With respect to the first issue, decided by the Tax Court in a consolidated case under the name Greenberg Bros. Partnership No. 4 v. Commissioner of Internal Revenue, 111 T.C. 198 (1998), petitioners-appellants and appellant Jo Ann Scarfia, who are partners in the partnerships, appeal on the ground that the Tax Court erred when it concluded that they were not entitled to a “consistent settlement” pursuant to 26 U.S.C. � 6224(c). *fn1 , *fn2

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