Jerry and Patricia A. Dixon, et al. - Page 80

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          the decisions entered on March 13, 1993, pursuant to Dixon II.              
          The letter advised that assessment of the taxes owing, plus                 
          statutory additions and interest, would be “approximately                   
          $302,396.12.”  The letter further noted:  “Of course, your                  
          clients’ advance payments will be credited toward the                       
          assessments.”                                                               
               DeCastro had several telephone conversations with                      
          respondent’s officials, in which he maintained that the Thompson            
          settlement, as memorialized in the August 3, 1989 letter                    
          agreement, was an enforceable contract, and that he was prepared            
          to appeal any decision to the contrary.                                     
               Bakutes prepared a motion that was filed in this Court on              
          June 9, 1992, seeking leave to vacate the decisions entered in              
          the Thompson cases, as well as the Cravens and the Rina cases.              
          Respondent requested the Court to conduct an evidentiary hearing            
          to determine whether the agreements with the Cravenses and the              
          Thompsons had affected the trial of the test cases or the ensuing           
          decisions of the Court.                                                     
               On June 10, 1992, Judge Goffe granted respondent’s motions             
          to vacate filed in the Thompson and the Cravens cases.  That same           
          day, Bakutes called DeCastro to tell him that the decisions in              
          the Thompson cases had been vacated.  During this call, DeCastro            
          told Bakutes that in 1988 McWade had reduced the Thompsons’                 
          deficiencies to keep the Thompsons in the case.  Although he had            





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