Robert Hunter Gridley and Barbara A. Gridley, et al. - Page 3

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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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