Jerry and Patricia A. Dixon, et al - Page 242




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               2.   William A. Sims                                                   
               In 1972, Mr. Sims began his career with the Office of Chief            
          Counsel, General Litigation Division, National Office.  Except              
          for a 6-month assignment doing Tax Court work, Mr. Sims handled             
          general litigation matters concerning collection, bankruptcy, and           
          tax liens.  Mr. Sims eventually became Assistant Director of the            
          General Litigation Division in the National Office.                         
               In February 1986, Mr. Sims was appointed District Counsel              
          for Honolulu, Hawaii.  Before his appointment as District                   
          Counsel, Mr. Sims had never worked on a tax shelter project in              
          any capacity.                                                               
          E.   Adoption of Test Case Procedures in Kersting Project                   
               1.   The Honolulu Session (June 1985)                                  
               The Court set for trial the cases of approximately 375                 
          Kersting program participants at a Tax Court session scheduled to           
          commence on June 10, 1985, in Honolulu, Hawaii (the June 1985               
          session).                                                                   
               Before the June 1985 session, Mr. McWade and Mr. Seery                 
          agreed to use the test case procedure in the Kersting project.              
          During the June 1985 session, Mr. McWade and Mr. Seery discussed            
          the use of the test case procedure with Judge Goffe during a                
          chambers conference.  During the conference, Mr. Seery informed             
          Judge Goffe that, although he was representing petitioners who              
          were Kersting program participants, he was being paid by Mr.                
          Kersting.  Judge Goffe indicated that he saw no conflict of                 
          interest as long as Mr. Seery had not participated in the                   

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