Jerry and Patricia A. Dixon, et al - Page 254




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               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 petitioner(s) in this case will testify or                
               provide information in any case involving the same tax                 
               shelter adjustments, if subpoenaed; and                                
                    6.  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                  
               shelter adjustments.                                                   
                    7.  If the Court determines the I.R.C. � 6621(d)                  
               penalties are applicable in the test case controlling                  
               petitioner's(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:                                                             
                         (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.                                                            



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