Jerry and Patricia A. Dixon, et al - Page 122




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          case petitioners that his cases had been settled was also                   
          reduced.                                                                    
               Messrs. Sims and McWade were the only persons in the                   
          Honolulu District Counsel Office with knowledge of the Thompson             
          and Cravens settlements before and during the trial of the test             
          cases.  Other than Mr. Stevens, no one else within the Internal             
          Revenue Service was aware of the Thompson and Cravens settlements           
          before or during the trial of the test cases through the times              
          that the Court issued its Dixon II opinion and entered the                  
          initial decisions in the test cases.                                        
               Before the trial of the test cases, Mr. McWade intentionally           
          misled the Court, with the complicity of Mr. DeCastro, by not               
          disclosing the settlement of the Thompson cases when he moved to            
          set aside the Thompson piggyback agreements.  At the trial of the           
          test cases, Messrs. Sims, McWade, and DeCastro intentionally                
          misled the Court regarding the status of the Thompson cases by              
          not disclosing the settlement of the Thompson cases.  At the                
          trial of the test cases, Messrs. Sims and McWade intentionally              
          misled the Court in similar fashion regarding the settlement of             
          the Cravens cases.                                                          
               Mr. McWade allowed Mr. Alexander to offer misleading                   
          testimony to the Court during the trial of the test cases                   
          regarding his understanding that his tax liabilities would be               
          reduced in exchange for providing assistance to Mr. McWade.                 
          Mr. DeCastro did not act as a Government "mole" during the                  
          trial of the test cases or convey any of Mr. Izen's trial                   

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