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Background3
These consolidated cases are part of a group of more than
1,300 remaining cases--more than 500 cases have settled--arising
from respondent's disallowance of interest deductions claimed by
participants in various tax shelter programs promoted by Henry
F.K. Kersting (Mr. Kersting) during the late 1970's through the
1980's. In 1989, by agreement of the parties and the Court, the
merits of the Kersting programs were litigated in a consolidated
trial of 14 docketed cases of eight petitioners that had been
designated as "test cases". At trial, six of the test case
petitioners were represented by Mr. Izen, test case petitioner
John R. Thompson was represented by Luis C. DeCastro (Mr.
DeCastro), and test case petitioner John R. Cravens appeared pro
se. The taxpayers in most of the remaining Kersting project
cases signed stipulations to be bound in which they agreed that
their cases would be resolved in accordance with the Court's
opinion in the test cases.
Following the trial of the test cases, the Court issued its
opinion sustaining virtually all of respondent's determinations
in each of the test cases, and entered decisions against the test
case petitioners in accordance with its opinion. See Dixon v.
Commissioner, T.C. Memo. 1991-614 (Dixon II).4 Shortly
3 The complete background of the these cases is set forth
in Dixon III and will not be repeated here.
4 Prior to the trial of the test cases, the Court had
(continued...)
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Last modified: May 25, 2011