- 25 - reduction of the deficiencies originally determined by respondent. On August 26, 1992, the Court denied respondent’s motion and held respondent to the pretrial concessions granted by Messrs. Sims and McWade in the new agreement as set forth in the August 3, 1989, letter agreement between Messrs. McWade and DeCastro. The Court granted Mr. DeCastro’s motions for entry of decision in the Thompson cases as follows: Year Deficiency Additions to Tax 1979 --- --- 1980 $15,000 --- 1981 15,000 --- Respondent did not appeal this Court’s decisions in the Thompson and the Cravens cases.17 As a result, the Cravenses and Mr. DeCastro’s clients, the Thompsons, had their cases closed, while the other test case petitioners, who had appealed the decisions entered in their cases, added the newly revealed facts about the misconduct of respondent’s attorneys to the grounds for their appeals. On September 14, 1992, Mr. Kersting wrote another “Dear Friend” letter to the participants in his tax shelter programs, 17As noted above, this Court had also denied the motion to vacate with respect to petitioner Ralph J. Rina, and he appealed. Unlike the Thompsons and the Cravenses, Mr. Rina had no settlement agreement with Messrs. Sims and McWade. On June 13, 1995, however, Mr. Rina agreed to entry of a stipulated decision in the amounts originally determined by respondent in his deficiency notice.Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
Last modified: May 25, 2011