Thomas R. and Margaret Kennedy - Page 3

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                        2.  The above adjustments, as specified in the                                    
                  preamble, shall be redetermined by application of the                                   
                  same formula as that which resolved the same tax                                        
                  shelter adjustments with respect to the following                                       
                  taxpayers:                                                                              
                               Names:  Melvin and Barbara Pinto                                           
                               Tax Court Docket No.:  17407-86                                            
                               (hereafter the CONTROLLING CASE)                                           
                        3.  All issues involving the above adjustments                                    
                  shall be resolved as if the petitioners in this case                                    
                  were the same as the taxpayers in the CONTROLLING CASE;                                 
                                                 * * *                                                    
                        5.  A decision shall be submitted in this case                                    
                  when the decision in the CONTROLLING CASE (whether                                      
                  litigated or settled) becomes final under I.R.C. �                                      
                  7481;                                                                                   
                                                 * * *                                                    
                        The parties agree to this STIPULATION OF SETTLEMENT.                              

                  Respondent filed a motion for entry of decision with this                               
            Court on October 30, 1995.  Attached as an exhibit to said motion                             
            was a decision document (the Document) that respondent claims to                              
            be in accordance with the stipulation.  By Order dated November                               
            7, 1995, the Court directed petitioners to show cause why                                     
            respondent's above-referenced motion should not be granted.                                   
            Petitioners filed their response on December 15, 1995.  They                                  
            contend that respondent's determination fails to account properly                             
            for a 1981 investment tax credit and a 1981 sales tax deduction.                              
                  By Order dated April 16, 1996, the Court directed respondent                            
            to address petitioners' above-referenced response.  On June 10,                               





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