Jerry and Patricia A. Dixon, et al - Page 77




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          I.   Closing of Cravens Cases                                               
               On July 1, 1992, Mr. Dombrowski wrote to the Cravenses                 
          enclosing documents that were intended to enable them to                    
          determine the proper decisions to be entered in their cases.                
          Mr. Dombrowski stated that, upon receipt of the Cravenses'                  
          response, he would coordinate the matter with Mr. Bakutes to                
          determine the terms of agreed decisions that respondent would be            
          willing to submit to the Tax Court.  On July 3, 1992, Mr. Cravens           
          responded to Mr. Dombrowski's letter with a written chronology of           
          the events leading to the settlement of his cases in December               
          1986.                                                                       
          On August 25, 1992, the Court entered agreed decisions in                   
          the Cravens cases consistent with the proposed decisions that               
          Mr. McWade forwarded to the Cravenses in December 1988.  The                
          decisions provide that the Cravenses are liable for deficiencies            
          for the taxable years 1979 and 1980 in the amounts of $3,606.40             
          and $6,175.76, respectively, and that the Cravenses are not                 
          liable for any additions to tax.  The decision for 1979 includes            
          a stipulation that the agreed deficiency does not take into                 
          account advance payments in the amounts of $4,508 and $6,000 that           
          the Cravenses made in May 1983 and December 1986, respectively.             
          The decision for 1980 includes a stipulation that the agreed                
          deficiency does not take into account an advance payment in the             
          amount of $4,678.67 that the Cravenses made in December 1986.               
          On October 26, 1992, the Regional Director of Appeals for                   
          the Western Region wrote a memorandum to the San Francisco                  

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