Jesse M. and Lura L. Lewis - Page 1

                                 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.               

                    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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