- 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
Last modified: May 25, 2011