Hoyt W. and Barbara D. Young, et al. - Page 4

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          Alfred Izen, Jr. (Izen) and Robert Alan Jones (Jones) in                    
          connection with the appeal of Dixon v. Commissioner, T.C. Memo.             
          1999-101, supplemented by T.C. Memo. 2000-116, revd. and remanded           
          316 F.3d 1041 (9th Cir. 2003).  Unless otherwise indicated,                 
          section references are to the Internal Revenue Code of 1986, as             
          amended, and Rule references are to the Tax Court Rules of                  
          Practice and Procedure.                                                     
          The following discussion is based on the existing record and                
          additional information submitted by the parties in connection               
          with the fee requests.  We have not found it necessary to hold an           
          evidentiary hearing.  See Rule 232(a)(2).                                   
               Petitioners Hoyt and Barbara Young (the Youngs) are test               
          case petitioners in the Kersting tax shelter litigation.  The               
          remaining petitioners herein (the Adairs, Alversons, McComases,             
          Baughmans, and Cerasolis) are nontest case petitioners whose                
          cases were consolidated with the test cases for purposes of the             
          attorney misconduct phase of this litigation, discussed below.              
          The Youngs and the Adairs (collectively, the Izen petitioners)              
          are represented by Izen; the remaining petitioners herein                   
          (collectively, the Jones petitioners) are represented by Jones.             
               The Kersting tax shelter litigation arose from respondent's            
          disallowance of interest deductions claimed by participants in              
          various tax shelter programs promoted by Henry F.K. Kersting                

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