Jerry and Patricia A. Dixon, et al - Page 263




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          appeared on behalf of respondent at the Maui session.                       
          Mr. DeCastro appeared at the Maui session on behalf of the                  
          Thompsons.  The Cravenses did not appear at the Maui session.               
               Following the Maui session, the Court ordered respondent and           
          petitioners, by May 18 and June 17, 1987, respectively, to file             
          opening and reply briefs addressing the evidentiary issues raised           
          by Chicoine and Hallett.  On motions by the parties, the Court              
          extended the dates for the filing of opening and reply briefs to            
          June 8 and August 10, 1987, respectively.                                   
               2.   Dixon I Opinion                                                   
               On February 11, 1988, the Court issued its Dixon I opinion             
          rejecting Chicoine and Hallett's evidentiary arguments.                     
          Specifically, the Court held that petitioners had failed to                 
          establish standing to contest the Kersting search.  Dixon v.                
          Commissioner, 90 T.C. 237 (1988).                                           
               By order dated July 1, 1988, the Court set the test cases              
          for trial in San Diego, California, on January 9, 1989.  By order           
          dated October 24, 1988, the Court granted Mr. Izen's motion to              
          reconsider and set the test cases for trial in Honolulu, Hawaii,            
          on January 9, 1989.                                                         
          V.   Kersting Disputes With Program Participants                            
               Before the trial of the test cases, Mr. Kersting had                   
          disputes, summarized below, with the Thompsons and the                      
          Alexanders.                                                                 





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