Jerry and Patricia A. Dixon - Page 4



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          thereafter, on June 9, 1992, respondent filed motions for leave             
          to file motions to vacate the decisions entered against the                 
          Thompsons, the Cravenses, and another test case petitioner, Ralph           
          J. Rina (Mr. Rina).  Respondent's motions to vacate alleged that,           
          prior to the trial of the test cases, respondent's trial                    
          attorney, Kenneth W. McWade (Mr. McWade), and his supervisor,               
          Honolulu District Counsel William A. Sims (Mr. Sims), had entered           
          into contingent settlement agreements with the Thompsons and the            
          Cravenses that had not been disclosed to the Court or to the                
          other test case petitioners or their counsel.  Respondent asked             
          the Court to conduct an evidentiary hearing to determine whether            
          the undisclosed agreements with the Thompsons and Cravenses had             
          affected the trial of the test cases or the opinion of the Court.           
          The Court granted respondent's motions to vacate filed in                   
          the Thompson and Cravens cases, vacated the decisions entered in            
          those cases, ordered the parties to file agreed decisions with              
          the Court, or otherwise move as appropriate, and denied                     
          respondent's request for an evidentiary hearing.  At the same               
          time, the Court denied respondent's motion to vacate the decision           
          entered against Mr. Rina on the ground that the testimony,                  
          stipulated facts, and exhibits relating to the Thompson and                 



          4(...continued)                                                             
          issued an opinion rejecting petitioners' arguments that certain             
          evidence should be suppressed and that the burden of proof should           
          be shifted to respondent.  See Dixon v. Commissioner, 90 T.C. 237           
          (1988) (Dixon I).                                                           




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