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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;
a. If the Court finds that any additions to tax or the
section 6621(c) interest are applicable to the
underpayment attributable to the above-designated tax
shelter adjustment(s), the resolution of the tax
shelter issue and the applicability of such addition to
tax or interest to that tax shelter issue in the
CONTROLLING CASE, whether by litigation or settlement,
shall apply to petitioner(s) as if the petitioner(s) in
this case was/were the same as the taxpayer(s) in the
CONTROLLING CASE;
4. If the adjustment is resolved in the CONTROLLING
CASE in a manner which affects the same issue in other
years (e.g., * losses in later years or affects
depreciation schedules), the resolution will apply to
petitioners’ later years as if the petitioners in this
case was/were the same as the taxpayer(s) in the
CONTROLLING CASE;
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