- 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,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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