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.3d 105

(9th Cir. 1994) (DuFresne), on remand Dixon v. Commissioner,

T.C. Memo. 1999-101

(Dixon III), supplemented by

T.C. Memo. 2000-116

(Dixon IV), revd. and remanded 316 F.3d 1041, 1047 (9th Cir. 2003) (Dixon…