T.C. Memo. 2005-205
UNITED STATES TAX COURT
JESSE M. AND LURA L. LEWIS,1 Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 15673-87, 18551-88, Filed August 29, 2005.
29429-88.
R determined deficiencies and additions to tax
against Ps and hundreds of other taxpayers who then
signed “piggyback agreements” with R, agreeing to be
bound by the outcome of selected test cases involving
tax shelter programs promoted by K. Before trial of
the test cases, R’s trial attorney, with his immediate
supervisor, entered into a secret settlement (not
disclosed to R’s management, the attorney for other
test case petitioners, or the Tax Court) with D,
attorney for test case petitioners T, arranging refunds
to the Ts sufficient to pay D’s attorney’s fees as
consideration for the Ts’ staying in the test case
array and T’s testifying at trial. After the Court
upheld R’s determinations and entered decisions in
favor of R in the test cases, R’s management discovered
1These cases have been consolidated for the sole purpose of
deciding the motions currently before the Court.
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