William Grant Lee - Page 5




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          outside the United States and, hence, outside the subpoena power            
          of this Court.  Respondent hoped to introduce testimony given by            
          these witnesses in the criminal trials into the record of the               
          civil trials.                                                               
               After the conclusion of the criminal trials against Mr.                
          Kilpatrick and Mr. O'Donnell, the proceedings in the GIG case               
          were further delayed because of several procedural motions on the           
          part of respondent and by Mr. O'Donnell's filing of so-called               
          Kelley motions to dismiss because of the expiration of the period           
          of limitations.  The parties litigated the Kelley motions all the           
          way to the Supreme Court.  The Supreme Court eventually ruled on            
          the motions.                                                                
               In or around December 1993, the Tax Court calendared the GIG           
          case for trial on February 6, 1995.                                         
               Around October 1994, Mr. O'Donnell withdrew as counsel in              
          the GIG case because of (1) a lack of communication with his                
          clients and (2) respondent's intention to call Mr. O'Donnell as a           
          witness in the civil trials.  Before Mr. O'Donnell's withdrawal,            
          respondent dealt with Mr. O'Donnell with respect to the GIG case.           
          After Mr. O'Donnell withdrew, respondent immediately began                  
          directly contacting petitioner concerning the GIG case.                     
               As of 1984, the IRS proposed settlement offers to the                  
          investors of the Kilpatrick shelter and a substantial number of             
          investors accepted.  In March 1995, petitioner accepted a                   
          settlement offer from respondent.  Pursuant to the settlement,              




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