Jerry and Patricia A. Dixon, et al - Page 10




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          Judge Goffe held the trial of the test cases in Honolulu,                   
          Hawaii, during January 1989.  The majority of the test case                 
          petitioners were represented at trial by Mr. Izen.  However, test           
          case petitioners John R. and Maydee L. Thompson (docket Nos.                
          19321-83, 31236-84, and 30965-85) were represented at trial by              
          Luis C. DeCastro (Mr. DeCastro), and test case petitioners John             
          R. and E. Maria Cravens (docket Nos. 16900-83 and 15135-84)                 
          appeared pro sese.                                                          
          Following the trial of the test cases, the Court issued its                 
          memorandum opinion in Dixon v. Commissioner, T.C. Memo. 1991-614,           
          62 T.C.M. (CCH) 1440, 1991 T.C.M. (RIA) par. 91,614 (Dixon II),             
          sustaining virtually all of respondent's determinations in each             
          of the test cases, and entered decisions against the test case              
          petitioners in accordance with its opinion.                                 
               On March 13, 1992, the Court entered the following decisions           
          in the Thompson and Cravens cases:                                          
          John R. and Maydee L. Thompson                                              
                      Additions to Tax                                                
          Sec.     Sec.      Sec.        Sec.                                         
          Year   Deficiency     6651(a)  6653(a)  6653(a)(1)  6653(a)(2)              
          1979   $18,161.00      ---   $908       ---        ---                      
          1980    24,838.00       ---      ---       ---        ---                   
          1981    36,294.52    $4,934.32   ---    $1,958.28  50 percent of            
          the interest                                                                
          due on the                                                                  
          deficiency                                                                  
          John R. and E. Maria Cravens                                                
          Additions to Tax                                                            
               Year            Deficiency            Sec. 6653(a)                     
               1979             $4,508.00              $225.40                        
               1980              5,893.45                294.67                       

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