Jerry and Patricia A. Dixon, et al - Page 68




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          taxpayer or taxpayer's representative in any Kersting project               
          case."                                                                      
               On or about June 11, 1992, Mr. Sanchez decided that                    
          Messrs. Sims and McWade should no longer have any authority over            
          the Kersting cases.  At that time, Mr. Bakutes reassigned all 14            
          test case dockets to Mr. Dombrowski, and all the nontest cases in           
          the Kersting project to Mr. O'Neill.  On June 12, 1992,                     
          Mr. Sanchez informed Mr. Sims that he had withdrawn Mr. Sims'               
          delegation of authority to settle any matters relating to the               
          Kersting project, and that management of the Kersting project was           
          reassigned to Mr. Bakutes.                                                  
               While Mr. Bakutes was carrying out his orders from                     
          Mr. Sanchez, Mr. Jordan directed two senior attorneys in the Tax            
          Litigation Division in the National Office, Thomas J. Kane                  
          (Mr. Kane), and Steven M. Miller (Mr. Miller), to investigate the           
          Thompson settlement on behalf of the National Office.                       
               Messrs. Kane and Miller conducted in-house depositions and             
          interviewed various individuals who had participated in the test            
          case trial and the Thompson settlement.  Mr. Bakutes directed               
          Mr. Dombrowski to provide information to aid Messrs. Kane and               
          Miller in their investigation.                                              
          E.   Disclosure of Cravens Settlement                                       
               The Cravens case for the 1980 taxable year was the only test           
          case that required a computation for entry of decision under Rule           
          155.  The computation was required in order to account for the              
          capital gain that the Cravenses had reported for 1980 on their              

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