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shelter programs (the Kersting project) promoted by Henry F.K.
Kersting (Kersting). Respondent’s determinations resulted in the
commencement in this Court of more than 1,800 cases arising from
the disallowance of deductions claimed by participants in the
Kersting programs. Most such participants who filed petitions in
this Court signed “piggyback agreements” with respondent,
agreeing to be bound by the outcome of test cases that had been
selected by respondent’s trial attorney and Brian Seery (Seery),
the attorney originally retained by Kersting to provide
representation in the Tax Court to participants in his programs.
Following Seery’s withdrawal, Kersting engaged Robert J.
Chicoine (Chicoine) and Darrell D. Hallett (Hallett) to represent
the participants in his programs in the Tax Court. Some such
participants, including the Thompsons (who were test case
petitioners), separately retained Luis C. DeCastro (DeCastro) to
represent them in the Tax Court.
DeCastro obtained 20-percent reduction settlements on behalf
of some of the Kersting project participants he represented, as
did Chicoine and Hallett on behalf of other nontest case
petitioners. Chicoine and Hallett disclosed the 20-percent
reduction settlement to the test case and nontest case
petitioners who had inquired about the possibility of a more
advantageous settlement than the 7-percent reduction project
settlement respondent had been offering.
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Last modified: May 25, 2011