United States Tax Court March 23, 2009, 9382-83, 15907-84, 30979-85 (Jerry and Patricia A. Dixon v. Commissioner)

132 T.C. No. 5

UNITED STATES TAX COURT

JERRY AND PATRICIA A. DIXON, ET AL.,1 Petitioners v.

COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket Nos. 9382-83, 15907-84, Filed March 23, 2009.

30979-85.

Ps’ cases were three of the Kersting tax shelter

test cases that were included in Dixon v. Commissioner,

T.C. Memo. 1991-614 (Dixon II), vacated and remanded

sub nom. DuFresne v. Commissioner, 26 F.