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Alfred Izen, Jr. (Izen) and Robert Alan Jones (Jones) in
connection with the appeal of Dixon v. Commissioner, T.C. Memo.
1999-101, supplemented by T.C. Memo. 2000-116, revd. and remanded
316 F.3d 1041 (9th Cir. 2003). Unless otherwise indicated,
section references are to the Internal Revenue Code of 1986, as
amended, and Rule references are to the Tax Court Rules of
Practice and Procedure.
Background
The following discussion is based on the existing record and
additional information submitted by the parties in connection
with the fee requests. We have not found it necessary to hold an
evidentiary hearing. See Rule 232(a)(2).
Petitioners Hoyt and Barbara Young (the Youngs) are test
case petitioners in the Kersting tax shelter litigation. The
remaining petitioners herein (the Adairs, Alversons, McComases,
Baughmans, and Cerasolis) are nontest case petitioners whose
cases were consolidated with the test cases for purposes of the
attorney misconduct phase of this litigation, discussed below.
The Youngs and the Adairs (collectively, the Izen petitioners)
are represented by Izen; the remaining petitioners herein
(collectively, the Jones petitioners) are represented by Jones.
The Kersting tax shelter litigation arose from respondent's
disallowance of interest deductions claimed by participants in
various tax shelter programs promoted by Henry F.K. Kersting
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