- 10 -
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withdrawn on December 31, 1986, (3) the elimination of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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