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surrender of their shares in Candace. An adjustment was also
required in order to eliminate respondent's alternative
determination that the Cravenses had unreported dividend income
for 1980. The Cravens case was the only test case presenting
these two issues.
On January 14, 1992, Mr. McWade forwarded a decision
document for the 1980 tax year to the Cravenses for their
signature. The decision was formulated by reference to the Tax
Court's December 11, 1991, opinion, as well as respondent's
computation for entry of decision, together with a computation
statement explaining how the decision was reached. Mr. O'Neill
prepared the aforementioned computations. Mr. O'Neill was not
aware at the time that Mr. McWade had entered into an agreement
to settle the Cravens cases before trial. The computation
statement accompanying respondent's computation for entry of
decision indicates that the proposed decision was based upon a
complete disallowance of the interest deductions listed in the
notice of deficiency issued to the Cravenses for 1980.
On January 30, 1992, the Cravenses signed the decision
documents and returned them to Mr. McWade. On February 4, 1992,
Mr. McWade signed the same documents and submitted them to the
Court. On March 13, 1992, the Court entered decisions in the
Cravens cases as follows:
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