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testimony of four witnesses over 2 days of trial, the relevant
facts are not in dispute and are easily summarized.
During 1980, 1981, 1982, and 1983, petitioner invested in
certain tax shelter partnerships (the tax shelters). Deductions
or losses stemming from the tax shelters were claimed on his
Federal income tax returns for those years. A deficiency was
determined for each of those years (the deficiency years). On
August 8, 1985, petitioner petitioned this Court for a
redetermination of the 1981 deficiency, and on June 5, 1986,
petitioner petitioned this Court for redeterminations of the
1980, 1982, and 1983 deficiencies (the deficiency cases).
The tax shelters generated approximately 1,100 Tax Court
cases. Most of the taxpayers involved in those cases were
represented by two attorneys (the project attorneys). Petitioner
was not. Instead, petitioner was represented by Attorney Robert
W. Taylor. After various pretrial proceedings and arrangements,
in 1987 a settlement was negotiated between the project attorneys
and respondent. Although not represented by the project
attorneys, petitioner was given the opportunity in 1987 to settle
the deficiency cases upon the same terms that the project
attorneys negotiated for their clients. Upon the advice and
recommendation of Mr. Taylor, petitioner rejected the settlement.
Seven years later, in 1994 petitioner accepted the settlement
offered to him in 1987. Stipulated decision documents reflecting
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