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On July 22, 1992, the test case petitioners represented by
Mr. Izen filed a motion for reconsideration of the Court's order
denying respondent's motion to vacate the decision in the Rina
case. By order dated August 4, 1992, Judge Goffe denied
petitioners' motion for reconsideration.
In August 1992, the Court entered revised decisions in the
Thompson and Cravens cases consistent with Mr. McWade's prior
agreements with the taxpayers in those cases. Specifically, the
Court entered the following decisions in the Thompson and Cravens
cases:
John R. and Maydee L. Thompson
Year Deficiency Additions to Tax
1979 --- ---
1980 $15,000 ---
1981 15,000 ---
John R. and E. Maria Cravens
Year Deficiency Additions to Tax
1979 $3,606.40 ---
1980 6,175.76 ---
The decisions entered in the Thompson and Cravens cases are now
final.2
2 Mr. Izen and Mr. Sticht filed separate motions with the
Court to intervene in the Thompson and Cravens cases. The Court
denied these motions to intervene. Although Mr. Izen and
Mr. Sticht filed separate appeals in the Thompson and Cravens
cases with various courts, including the Courts of Appeals for
the Second, Ninth, and Tenth Circuits, all appeals in the
Thompson and Cravens cases eventually were dismissed. In an
unpublished opinion filed June 15, 1994, the Court of Appeals
for the Ninth Circuit stated:
(continued...)
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