- 44 - After the lead counsel for the taxpayers and respondent agreed upon the test cases, respondent prepared a piggyback agreement with respect to the Plastics Recycling project so that taxpayers who did not wish to litigate their cases individually could agree to be bound by the results of the test cases. Fisher v. Commissioner, supra; Estate of Satin v. Commissioner, supra. The piggyback agreement, as set forth in the Fisher and Estate of Satin cases, provides as follows: With respect to all adjustments in respondent’s notice of deficiency relating to the Plastics Recycling tax shelter, the parties stipulate the following terms of settlement: 1. THE ABOVE ADJUSTMENT IS THE ONLY ISSUE IN THIS CASE; 2. The above adjustment(s), as specified in the preamble, shall be determined by application of the same formula as that which resolved the same tax shelter adjustments with respect to the following taxpayer(s): Names(s): Harold M. Provizer and Joan Provizer v. Commissioner of Internal Revenue Tax Court Docket No.: 27141-86 Names(s): Elliot I. Miller v. Commissioner of Internal Revenue Tax Court Docket No.: 10382-86 Names(s): Elliot I. Miller and Myra K. Miller v. Commissioner of Internal Revenue Tax Court Docket No.: 10383-86 (hereinafter the CONTROLLING CASE) 3. All issues involving the above adjustment(s) shall be resolved as if the petitioner(s) in this case was/were the same as the taxpayer(s) in the CONTROLLING CASE;Page: Previous 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 Next
Last modified: May 25, 2011