Robert Hunter Gridley and Barbara A. Gridley, et al. - Page 5

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                    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.                                                     



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