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On September 18, 1989, Louis Samuel filed the petition for
petitioner and Lincir in the 1989 case. On January 21, 1992,
Michael D. Savage (petitioner’s counsel in the instant case)
entered his appearance in the 1989 case. On April 9, 1992, the
petition in the 1989 case was amended to claim innocent spouse
treatment for petitioner under section 6013(e) as it then
existed. On July 1, 1992, the parties in the 1989 case entered
into a stipulated settlement of certain of the tax shelter
issues. The 1989 case was set for trial in Los Angeles and then
continued generally. There followed numerous orders, reports,
and a stipulation of facts, and the 1989 case was set for trial
in San Francisco. The 1989 case was again continued and again
set for trial in San Francisco. The 1989 case was then
consolidated with numerous other dockets, then some of those
dockets were severed from the consolidated group, then the trial
for the remaining dockets in the consolidated group (including
the 1989 case) was again continued, and again set to take place
in San Francisco. On August 1, 1996, petitioner and Lincir
entered into a stipulation of settled issues relating to certain
tax shelter issues, agreeing to be bound by the determinations as
to those issues in certain designated lead cases. On August 15,
1996, the 1989 case was severed from consolidation. On January
30, 1997, there was a 1-day trial in the 1989 case. At the
conclusion of the trial in the 1989 case, the parties thereto
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