- 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.
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