Sharon E. Backstrom, Harold J. and Zelma G. Barbret, Virginia Boland, John A. and Theresa A. Cislaghi, Estate of Roger W. Dornbrock, Gary E. and Beverly G. Engel, Hermann K. and Helen W. Enzmann, - Page 6

                                        - 6 -                                         

          were severed from the lead cases and assigned to this case.  In             
          due course, a notice was issued calendaring this case for trial.            
               The lead cases in the program that were tried were decided             
          by this Court in Donahue v. Commissioner, T.C. Memo. 1991-181,              
          affd. without published opinion 959 F.2d 234 (6th Cir. 1992),               
          affd. sub nom. Pasternak v. Commissioner, 990 F.2d 893 (6th Cir.            
          1993).  In Donahue v. Commissioner, supra, this Court found that            
          the Pop Phonomasters program lacked economic substance.  The                
          decision in the Donahue case was affirmed in the two cited                  
          appeals.  Subsequent to the conclusion of the final appeal in the           
          Donahue case and the expiration of time for filing a petition for           
          certiorari with the U.S. Supreme Court, counsel for the parties             
          in this case, which included the Dornbrocks, entered into a                 
          stipulated decision with respect to the Pop Phonomasters issues             
          based on the decisions in the Donahue case.                                 
               In the stipulated decision entered in this case, the parties           
          agreed to deficiencies in Federal income taxes and additions to             
          tax with regard to Mr. and Mrs. Dornbrock in the amounts set out            
          in the notice of deficiency.  The stipulated decision document              
          was lodged with the Court when the case was called for trial on             
          November 1, 1993, and the decision was entered by the Court on              
          December 23, 1993.  Concurrent with the filing of the                       
          stipulation, the parties filed a Motion to Substitute Parties and           
          to Change Caption with respect to petitioner Roger W. Dornbrock,            





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