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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 24, 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 petitioner to show cause why
respondent's above-referenced motion should not be granted.
Petitioner filed his response on December 15, 1995. He contends
that the notice of deficiency fails to account properly for an
investment tax credit.
By Order dated April 16, 1996, the Court directed respondent
to address petitioner's above-referenced response. On June 10,
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Last modified: May 25, 2011