- 3 - argue that interest on the deficiencies should not be charged beyond Dec. 31, 1986, which, in their view, marks the inception of the fraud on the court. R has conceded that no interest will be charged on the deficiencies for the period of the appeals to the Ninth Circuit commencing in 1992. Held: The final settlement of T’s 1979-1981 deficiencies amounts to a 62.17-percent reduction of those deficiencies. Held, further: Two minor additional benefits included in the T settlement bring the reduction percentage up to 63.37 percent. Held, further: The T settlement encompasses and requires the vacating of the portion or portions of the deficiencies determined against any Ps that may be attributable to the “Bauspar” shelter that was also promoted by Kersting and to any other issues not arising from shelters promoted by Kersting. Held, further: Interest on the reduced deficiencies shall not be charged beyond the date in 1992 fixed by R’s concession and shall not be stopped as of any earlier date. Henry G. Binder and John A. Irvine, for petitioners in docket Nos. 9382-83, 15907-84, and 30979-85. Joe Alfred Izen, Jr., for petitioners in docket Nos. 17642-83, 4201-84, 38965-84, 40159-84, 22783-85, 30010-85, 35608-86, 479-89, and 8070-90. Robert Alan Jones, for petitioners in docket Nos. 17646-83, 10931-84, 38757-84, 19464-92, 621-94, and 9532-94. Declan J. O’Donnell, for petitioners in docket Nos. 10588-83, 27053-83, 28723-84, and 13477-87.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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