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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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