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(a) Respondent concedes that the
petitioner(s) are not liable for additions to tax under
I.R.C. � 6653(a) or � 6653(a)(1) or � 6653(a)(2) for
any year prior to the taxable year 1982.
The parties agree to this stipulation of
settlement.
On September 21, 1987, the Fleers executed a piggyback agreement
identical to the 1986 piggyback agreement and filed the same with
the Court in docket No. 13477-87.
Test Case History
On December 11, 1991, following a trial on the merits of the
test cases, the Court issued its Memorandum Opinion sustaining
virtually all of respondent's determinations in each of the test
cases. See Dixon v. Commissioner, T.C. Memo. 1991-614.
Thereafter, the Court entered decisions in the test cases in
accordance with the Court's opinion.
On June 10, 1992, the Court granted leave and filed
respondent's motions to vacate the decisions in the test cases of
John Thompson (docket Nos. 19321-83, 31236-84, and 30965-85) and
John Cravens (docket Nos. 16900-83 and 15135-84). Respondent
stated in her motions to vacate that she believed her lead
counsel in the trial of the test cases had, prior to trial,
entered into contingent settlement agreements with Thompson and
Cravens that were not made known to the Court or to the other
parties in the test cases, and that the decisions entered by the
Court in those dockets did not accurately reflect the prior
agreements. Respondent's motions to vacate requested a hearing
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