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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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