Jesse M. and Lura L. Lewis - Page 60

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          counsel were also aware that test case petitioners represented by           
          Mr. Izen had appealed the Tax Court’s decisions, which had                  
          sustained respondent’s determinations despite the revelation of             
          the misconduct of Messrs. Sims and Mcwade.  The finality of the             
          stipulated decisions in petitioners’ cases precludes them from              
          participating in the relief mandated by the Court of Appeals in             
          Dixon V to other Kersting project petitioners who did not accept            
          respondent’s January 1993 settlement offer.                                 
               In view of the foregoing,                                              

                                             Orders will be issued denying            
                                        petitioners’ motions for leave to             
                                        file motions to vacate decisions,             
                                        as supplemented.                              

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