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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 13, 1995. They
contend that respondent's determinations involve incorrect
calculations and suggest that corrections are necessary before a
decision can be entered in this case. More specifically,
petitioners claim that respondent's determinations fail to
account for their pro rata share of a partnership deduction
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Last modified: May 25, 2011