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January 29, 1993. Petitioners were given 60 days within which to
accept or reject the settlement. In a letter dated March 11,
1993, Mr. O’Donnell informed respondent’s counsel, Mr. O’Neill,
that petitioners herein had decided to accept the settlement
proposal. Thereafter, respondent forwarded a stipulated decision
document to petitioners’ counsel reflecting a disposition of
these cases on the settlement terms set forth in the mass
mailings.19 On May 17, 1993, Mr. O’Donnell signed the decision
documents in docket Nos. 15673-87 and 18551-88; on May 18, 1993,
Mr. Jones signed the decision document in docket No. 29429-88.
On June 16, 1993, Mr. O’Neill signed petitioners’ decision
documents on behalf of respondent.
The decisions entered in petitioners’ cases reflected a
reduction of the proposed deficiencies by 7 percent to $3,276 for
1984 and $2,552 for 1986; the stipulated deficiency for 1983 was
reduced from $935 to $314, some $556 less than the $870 figure
that would have resulted from a reduction of the original
deficiency by 7 percent.20 The decisions provided there would be
no additions to tax and that no part of the deficiencies
19Respondent extended the settlement proposal to all known
Kersting non-test-case petitioners in mass mailings in January
1993. Respondent reports that taxpayers accepted the proposal in
approximately 400 cases. Overall, between 1991 and the present,
stipulated decisions were filed in approximately 750 Kersting
project cases.
20The record does not explain this discrepancy, nor is it
relevant for purposes of the pending motions.
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