Perry D. McBroom, Deceased, and Jackie S. McBroom - Page 3

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            Commissioner, T.C. Memo. 1989-568.  The Bales case involved like                          
            cattle breeding partnerships formed by Walter J. Hoyt III.                                
                  At the pretrial hearing, Jim B. Dismukes filed a motion to                          
            withdraw as counsel, which was granted.  In addition, respondent                          
            filed an Amendment to Answer in which she determined an increased                         
            deficiency and additions to tax.  On October 12, 1993, respondent                         
            filed a status report informing the Court that petitioner Perry                           
            D. McBroom (Mr. McBroom) died on April 16, 1989, and that                                 
            petitioner Jackie S. McBroom (petitioner) was interested in                               
            settling the case with respondent.  Mr. McBroom died intestate in                         
            California, a community property State, and was survived by                               
            petitioner and adult children residing in Texas.                                          
                  Petitioner accepted respondent's Appeals Office offer, on or                        
            about September 27, 1993.  However, petitioner failed to comply                           
            with the terms of the settlement offer.  On June 30, 1994,                                
            respondent served on petitioner and her counsel, Joel Drum,                               
            Respondent's First Request for Admissions Addressed to the                                
            Petitioner Jackie S. McBroom requesting that the facts set forth                          
            therein be admitted or denied.  Pursuant to Rule 90, respondent's                         
            request was filed with this Court on July 5, 1994.  Petitioner                            
            did not respond.                                                                          
                  The case was calendared for trial at a special session                              
            beginning on October 26, 1994, in San Francisco, California.  On                          
            August 12, 1994, respondent filed the pending Motion for Summary                          
            Judgment, wherein she concedes the additions to tax under                                 




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