Robert Hunter Gridley and Barbara A. Gridley, et al. - Page 6

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                    1.  The Kersting interest deduction tax shelter                   
               adjustments shall be redetermined on the same basis                    
               that the same tax shelter adjustments are resolved with                
               respect to taxpayers trying the same shelter                           
               adjustments at the February 9, 1987 session of the                     
               Court in Wailuku, Maui, Hawaii, or such session as                     
               these cases may be adjourned or continued to by the                    
               Court (hereinafter "TRIED CASE").                                      
                    2.  All issues involving the Kersting interest                    
               deduction tax shelter(s) shall be resolved as if the                   
               petitioner(s) in this case is the same as the taxpayers                
               in the TRIED CASE;                                                     
                    3.  A decision shall be submitted in this case                    
               when the decision in the TRIED CASE becomes final under                
               I.R.C. � 7481;                                                         
                    4.  Following entry of the decision in this case,                 
               petitioner(s) consent 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);                                                             
                    5.  The petitioners in this case will testify or                  
               provide information in any case involving the same tax                 
               shelter adjustments, if subpoenaed; and                                
                    6.  The petitioners in this case consent 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                  
               shelter adjustments.                                                   
                    7.  If the Court determines the I.R.C. � 6621(d)                  
               penalties are applicable in the test case controlling                  
               petitioner'(s’) case, then the petitioner(s) concedes                  
               that I.R.C. � 6621(d) is applicable to any underpayment                
               of tax determined in their case(s) attributable to the                 
               Kersting interest deduction tax shelter(s), if such                    
               underpayment exceeds $1,000.00 in any one taxable year.                
                    8.  With respect to adjustments in respondent's                   
               notice of deficiency relating to additions to the tax                  
               under I.R.C. � 6653(a), the parties agree to the                       
               following:                                                             





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