Jerry and Patricia A. Dixon, et al - Page 15




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          Mr. Cravens' returns for years still open under the applicable              
          statute of limitations to determine whether he had claimed                  
          Kersting deductions for years not before the Tax Court.                     
          Mr. McWade initially told Mr. Cravens that his settlement                   
          assured that the Cravenses could not win or lose in the trial of            
          the test cases.  Mr. McWade also told Mr. Cravens that, by reason           
          of the settlement, the Cravenses did not need an attorney.                  
          Mr. Cravens therefore concluded that he no longer needed legal              
          representation.  When Mr. Cravens asked Mr. McWade why he had to            
          remain a test case despite his settlement, Mr. McWade responded             
          that to remove the Cravenses from the group of test cases would             
          cause a delay in the trial of the test cases while a replacement            
          test case was selected.                                                     
               After Mr. Seery's withdrawal from their cases, the Cravenses           
          did not retain new counsel.  When Mr. Kersting asked Mr. Cravens            
          why the Cravenses had failed to authorize Chicoine and Hallett to           
          represent them, Mr. Cravens informed Mr. Kersting that he had               
          settled his cases.                                                          
          On December 13, 1988, within 1 month before the trial of the                
          test cases, which began January 9, 1989, Mr. McWade forwarded to            
          the Cravenses proposed decision documents fixing their tax                  
          liabilities for 1979 and 1980, to be signed and returned to                 
          Mr. McWade.  The proposed decision documents provided as follows:           







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