Wallace and Donnetta Duncan, et al. - Page 14

                                       - 14 -                                         
          binding on the parties, both parties also recognize that there              
          are additional legal issues present in these docketed cases which           
          may give rise to further legal proceedings, including if                    
          necessary, a Tax Court trial.                                               
               The parties further agree that while the Findings are not              
          binding on any other participants in the various FMF gas well               
          enterprises who are not petitioners in this consolidated group of           
          Tax Court cases, there is no prohibition against offering the               
          Arbitrator’s factual Findings as evidence in any subsequent court           
          proceeding concerning these docketed cases or any other                     
          proceeding.  Any settlement reached by the parties through the              
          Arbitration, however, shall not serve as an estoppel in any other           
          proceeding.                                                                 
               6.  CONFIDENTIALITY.  Petitioners acknowledge that the                 
          Arbitrator (and any agents he may use during the arbitration                
          process) may have access to Petitioners’ returns and return                 
          information pertaining to the Issues being arbitrated.                      
          Respondent’s agents involved in the arbitration and the                     
          Arbitrator (and any agents he may use during the arbitration                
          process), are subject to the confidentiality and disclosure                 
          provisions of I.R.C. �� 6103(n), 6103, 7213 and 7431.  The                  
          parties acknowledge that employees of the Service and all other             
          Treasury employees involved in this arbitration are bound by                








Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next

Last modified: May 25, 2011