Jerry and Patricia A. Dixon, et al - Page 72




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               portions relating specifically and expressly to the                    
               Cravenses or the Thompsons), and the Court's findings,                 
               analyses, and conclusions relating to petitioner Rina                  
               would remain the same.  * * *                                          
          G.   Attempted Discovery by Counsel for Nontest Case Petitioners            
          By letters dated June 24 and August 12, 1992, Messrs. Jones                 
          and O'Donnell jointly requested that Mr. Dombrowski provide                 
          informal discovery regarding the Thompson and Cravens                       
          settlements.  The earlier of the two letters included allegations           
          that Mr. Kersting withheld documents from the test case                     
          petitioners that would have described "an underlying business of            
          great substance" because Mr. Kersting feared that the information           
          would increase his personal tax liability.  Respondent declined             
          to respond to the informal discovery requests and did not allow             
          Messrs. Jones and O'Donnell to participate in any of the in-house           
          investigations conducted by Messrs. Bakutes, Dombrowski, Kane,              
          and Miller.                                                                 
          H.   Closing of Thompson Cases/Further Refunds                              
               In July 1992, Mr. DeCastro filed a motion for entry of                 
          decision in accordance with the terms of the Thompson settlement            
          set forth in Mr. DeCastro's letter to Mr. McWade dated August 3,            
          1989; i.e., deficiencies of zero, $15,000, and $15,000 for the              
          taxable years 1979, 1980, and 1981, respectively.  On August 20,            
          1992, respondent filed objections, with respondent's Motions for            
          Entry of Decision and respondent's Memoranda of Points and                  
          Authorities, to Mr. DeCastro's motion for entry of decision.                
          Respondent's Motions for Entry of Decision described the facts              


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