Robert Hunter Gridley and Barbara A. Gridley, et al. - Page 4

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          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.                                                                



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