Jesse M. and Lura L. Lewis - Page 25

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          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.                                                          





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