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cases, a large number of taxpayers, including petitioners,
executed one of two stipulations, entitled Stipulation of
Settlement for Tax Shelter Adjustments (piggyback agreements), by
which they agreed to be bound by the outcome in the test cases.
The motions for summary judgment filed in these cases are
identical in all material respects. We observe, however, that
the piggyback agreements relied upon by petitioners, although
similar, can be distinguished depending upon whether they were
executed and filed with the Court in 1985 or in later years. For
the sake of completeness, the two piggyback agreements are set
forth in their entirety below.
Robert and Barbara Gridley
Respondent determined deficiencies in and additions to
Robert and Barbara Gridley’s Federal income taxes for 1978, 1979,
1980, and 1981 based upon the disallowance of Kersting-related
interest deductions. Petitioners contested respondent's
determinations by filing timely petitions for redetermination
assigned docket Nos. 10588-83, 10931-84, and 38757-84.5
In May 1985, Brian J. Seery, Esq. (Mr. Seery), entered his
appearance in each of the Gridleys' three docketed cases.
Shortly thereafter, Mr. Seery executed a Stipulation of
Settlement For Tax Shelter Adjustments (the 1985 piggyback
5 At the time the petitions were filed, the Gridleys resided
in San Jose, California.
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