- 5 - 7. The petitioner(s) in this case consents to the disclosure of all tax returns and tax return information for the purpose of respondent's discovering or submitting evidence in any case involving the same Kersting program adjustments. The parties agree to this stipulation of settlement. Russell and Sally Fleer Respondent determined deficiencies in and additions to Russell and Sally Fleer’s Federal income taxes for 1980 and 1983 based upon the disallowance of Kersting-related interest deductions. The Fleers contested respondent's determinations by filing timely petitions for redetermination assigned docket Nos. 27053-83 and 13477-87.7 In February 1986, Mr. Seery entered his appearance in docket No. 27053-83. On November 24, 1986, Mr. Seery executed a Stipulation of Settlement For Tax Shelter Adjustments (the 1986 piggyback agreement) on the Fleers’ behalf that was filed with the Court on December 1, 1986.8 The 1986 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: 7 At the time the petitions were filed, the Fleers resided in Thousand Oaks, California. 8 Brian J. Seery, Esq., subsequently withdrew as the Fleers' counsel in docket No. 27053-83. On Aug. 17, 1992, Declan J. O'Donnell, Esq., filed an entry of appearance in both of the Fleers’ docketed cases.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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