- 4 - agreement) on the Gridleys' behalf that was filed with the Court on June 10, 1985.6 The 1985 piggyback agreement states: Stipulation of Settlement for Tax Shelter Adjustments With respect to all adjustments in respondent's notice of deficiency relating to the Kersting interest deduction tax shelter(s), the parties stipulate to the following terms of settlement: 1. The term Kersting programs refers to interest expense deductions or other related deductions associated with various programs promoted by Henry Kersting. 2. The Kersting program deduction adjustments shall be redetermined on the same basis that the same program adjustments are resolved with respect to taxpayers trying the same program adjustments at the June 10, 1985 session of the Court in Honolulu, Hawaii, or such session as these cases may be adjourned or continued to by the Court (hereinafter "TRIED CASE"). 3. All issues involving the Kersting programs shall be resolved as if the petitioner(s) in this case is the same as the taxpayers in the TRIED CASE; 4. A decision shall be submitted in this case when the decision in the TRIED CASE is entered; 5. Following entry of the decision in this case, petitioner(s) consents to the assessment and collection of the deficiencies, attributable to the adjustments formulated by reference to the Tax Court's opinion, notwithstanding the restrictions contained in I.R.C. �6213(a); 6. The petitioner(s) in this case will testify or provide information in any case involving the same tax shelter adjustments, if subpoenaed; and 6 Brian J. Seery, Esq., subsequently withdrew as the Gridleys' counsel. In August 1992, Declan J. O'Donnell, Esq., filed an entry of appearance on behalf of the Gridleys in each of their cases.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011