Dorchester Industries Incorporated, et al. - Page 13

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          question of an innocent spouse defense for Mary Wheaton.  Mary              
          Wheaton said that she did not want to raise that defense.  Frank            
          Wheaton said that he was not going to have that defense raised.             
               Gilson and Wodlinger have withdrawn as counsel in all of the           
          docketed cases.                                                             
                                       OPINION                                        
          I.  Introduction                                                            
               Respondent has moved for entry of decision in each of these            
          consolidated cases in accordance with a settlement agreement of             
          the parties.  Because respondent and petitioner Mary Wheaton                
          (Mary Wheaton) have since reached an agreement on and have                  
          stipulated to the fact that Mary Wheaton is an innocent spouse              
          within the meaning of section 6013(e), there are no issues with             
          respect to Mary Wheaton that we must address.  With respect to              
          petitioners Dorchester Industries Inc. (Dorchester) and Frank               
          Wheaton, Jr. (Frank Wheaton), we must determine whether those               
          parties and respondent, in fact, entered into a settlement                  
          agreement and, if so, the consequences thereof.                             
               At the conclusion of an evidentiary hearing that commenced             
          on July 26, 1996 (the hearing), the parties (other than Mary                
          Wheaton) were directed to file briefs setting forth proposed                
          findings of fact and argument.  The Court set page limitations on           
          the argument portions of the opening and answering briefs of                
          25 and 15 pages, respectively.  The Court stated that, if                   
          additional pages for argument were desired, a party would have to           




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