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MEMORANDUM OPINION
BEGHE, Judge: These consolidated cases are before the
Court on petitioners' Motions for Summary Judgment. Petitioners
contend that they are entitled to entry of decision consistent
with the decision entered by the Court in the case of John R. and
Maydee L. Thompson, docket No. 19321-83. As explained in greater
detail below, we will deny petitioners' motions.3
Background
These cases are part of a large tax shelter project,
currently comprising more than 1,300 cases, arising from the
Commissioner's disallowance of interest deductions claimed by
participants in investment programs created and administered by
Henry Kersting (Kersting group cases). Due to the large number
of Kersting group cases, and the variety of investment programs,
the Commissioner and taxpayer representatives selected 14 dockets
as test cases to resolve the issues common to all of the cases.4
In conjunction therewith, and in advance of the trial of the test
3 All section references are to the Internal Revenue Code in
effect for the years in issue, unless otherwise indicated. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
4 The 14 dockets consolidated as test cases include Jerry
and Patricia A. Dixon, docket No. 9382-83; John R. and E. Maria
Cravens, docket Nos. 16900-83 and 15135-84; Ralph J. Rina, docket
No. 17640-83; John R. and Maydee L. Thompson, docket Nos. 19321-
83, 31236-84 and 30965-85; Hoyt W. and Barbara D. Young, docket
Nos. 4201-84, 22783-85, and 30010-85; Robert L. and Carolyn S.
DuFresne, docket Nos. 15907-84 and 30979-85; Terry D. and Gloria
K. Owens, docket No. 40159-84; and Richard and Fidella
Hongsermeier, docket No. 29643-86.
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