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production of the more than 200 documents and items encompassed
by respondent’s privilege log, as being relevant to that purpose.
In Dixon VI, we held that: (1) The final Thompson
settlement is to be regarded as resulting in a 63.37-percent
reduction of the Thompsons’ deficiencies, as well as elimination
of all Kersting-related penalties and additions; (2) the Thompson
settlement encompasses and requires the vacating of the portion
or portions of the deficiencies determined against any
petitioners that may be attributable to the “Bauspar” shelter
that was also promoted by Kersting; (3) the Thompson settlement’s
cancellation of the Thompsons’ 1981 late-filing addition
justifies cancellation of not only all non-Kersting-related
penalties and additions but also all other substantive
adjustments not arising from shelters promoted by Kersting; (4)
interest on the reduced deficiencies shall not be charged beyond
the date in June 1992 fixed by respondent’s concession and shall
not be stopped as of any earlier date, such as December 1986,
which petitioners contend marked the inception of the fraud on
the court.
9(...continued)
entered in response to respondent’s project settlement offer of
January 1993 and other settlements of Kersting project cases.
See supra note 4.
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