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          Messrs. Cravens, Thompson, Moseley, and Kersting, and the direct            
          examination of Messrs. Kersting, Toyota, Ing, and Alexander.                
          Mr. Dombrowski conducted the direct examination of Alice Combs              
          and Margo Akamine, Mr. Kersting's bookkeepers.                              
          A.   Mr. Cravens                                                            
          Following Mr. Seery's withdrawal from the Cravens cases in                  
          early 1987, Mr. Cravens did not retain substitute counsel because           
          he regarded his cases as settled.  Mr. Cravens arrived in Hawaii            
          1 day before he was scheduled to testify at the trial of the test           
          cases.  The Government paid Mr. Cravens' travel, food, and                  
          lodging expenses while he was in Hawaii.53                                  
               Mr. McWade prepared and submitted to the Court requested               
          findings of fact respecting Mr. Cravens' participation in the               
          disputed Kersting programs.  When Mr. Cravens testified during              
          the trial of the test cases, he made a brief statement to the               
          Court about his participation in the Kersting programs, told the            
          Court and the parties that he had absolutely nothing to hide, and           
          said that he would answer any questions to the best of his                  
          ability.                                                                    
               Mr. McWade cross-examined Mr. Cravens at the trial and                 
          elicited testimony to support respondent's proposed finding of              
          fact that Mr. Cravens' primary reason for participating in the              
          Kersting programs was to obtain tax benefits.  Mr. Cravens                  
          53  Inasmuch as respondent subpoenaed all the test case                     
          petitioners, it is assumed that they were all reimbursed for                
          their expenses.  See sec. 7610.                                             
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