Jerry and Patricia A. Dixon - Page 10




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          response, Mr. Izen filed a further supplement and an affidavit              
          stating that he had received $425,352.82 in attorney's fees from            
          the Don Belton Legal Defense Fund (the Belton fund).  Mr. Izen              
          also submitted a spreadsheet purporting to show the amount of the           
          individual contributions that petitioners and hundreds of other             
          participants in the Kersting tax shelter programs had made to the           
          Belton fund.                                                                
               Mr. Sticht's Motion For Sanctions                                      
               On January 4, 2000, Mr. Sticht filed a motion for sanctions            
          and a supporting memorandum on behalf of the Rinaldis.7  Mr.                
          Sticht contends that the Court should use its inherent power to             
          impose sanctions on respondent, including (1) an award of                   
          petitioners' attorney's fees and costs, (2) an adjustment to                
          petitioners' tax liabilities for taxable years prior to 1987 to             
          reflect a 20-percent settlement offer by respondent that was                
          withdrawn on December 31, 1986, (3) the elimination of                      
          petitioners' tax liabilities for taxable years after 1986, and              
          (4) the elimination of petitioners' liability for statutory                 



          7  In addition to the petition assigned docket No. 7205-94,                 
          in which the Rinaldis challenge Kersting-related adjustments                
          affecting their tax liabilities for 1990 and 1991, the Rinaldis             
          have filed petitions challenging Kersting-related adjustments for           
          the tax years 1980 (docket No. 31065-83), 1983 (docket No. 21615-           
          87), 1984 and 1985 (docket No. 6981-89), 1986 and 1987 (docket              
          No. 11439-90), 1988 (docket No. 27556-90), and 1989 (docket No.             
          14907-93).  The other petitioners who participated in the                   
          evidentiary hearing through Mr. Sticht’s representation were not            
          included in the motion.                                                     





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