Jerry and Patricia A. Dixon, et al - Page 246




                                       - 38 -                                         

          1986, Mr. McWade notified Judge Goffe that he and Mr. Seery had             
          selected the following 14 dockets to serve as test cases with               
          respect to the Kersting project:                                            
                     Case Name                     Docket No.                         
               Dixon v. Commissioner                 9382-83                          
               Cravens v. Commissioner              16900-83                          
               Rina v. Commissioner                 17640-83                          
               Thompson v. Commissioner             19321-83                          
               Young v. Commissioner                 4201-84                          
               Cravens v. Commissioner              15135-84                          
               DuFresne v. Commissioner             15907-84                          
               Thompson v. Commissioner             31236-84                          
               Owens v. Commissioner                40159-84                          
               Young v. Commissioner                22783-85                          
               Young v. Commissioner                30010-85                          
               Thompson v. Commissioner             30965-85                          
               DuFresne v. Commissioner             30979-85                          
               Hongsermeier v. Commissioner         129643-86                         
               1 By order dated Aug. 13, 1986, the Court severed the                  
          Hongsermeiers from docket No. 17445-82 (the Aaronson consolidated           
          petition filed by Mr. Nevels) and assigned them new docket No.              
          29643-86.  See supra note 18 and accompanying text.                         

               With the exception of the Cravens case assigned docket No.             
          16900-83, and the Hongsermeier case assigned docket No. 17445-82,           
          each of the test case petitioners had filed pro se petitions.  By           
          August 1986, Mr. Seery had entered his appearance in each of the            
          test cases with the exception of the Young cases assigned docket            
          Nos. 4201-84, 22783-85, and 30010-85, the DuFresne case assigned            
          docket No. 30979-85, and the Thompson case assigned docket No.              
          30965-85.                                                                   
               3.   Test Case Array                                                   
               The test case petitioners had participated in Kersting                 
          programs during the taxable years 1975 through 1983 as follows:             


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