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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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