- 45 -
relating specifically and expressly to the Cravenses or
the Thompsons), and the Court’s findings, analyses, and
conclusions relating to petitioner Rina would remain
the same. * * *[19]
During the summer of 1992, respondent’s Acting Chief Counsel
David Jordan (Jordan) directed two senior attorneys in the Tax
Litigation Division in the National Office, Thomas J. Kane (Kane)
and Steven M. Miller (Miller), to investigate the Thompson
settlement on behalf of the National Office. Kane and Miller
conducted in-house depositions and interviewed various
individuals who had participated in the test case trial and the
Thompson settlement.
Bakutes assigned Dombrowski to help Kane and Miller in their
investigation. Dombrowski’s immediate problem was how to respond
to this Court’s order of June 22, 1992, that the parties file
agreed decisions with the Court or otherwise move within 30 days.
Dombrowski learned that McWade and Sims had denied that the
purpose of the new agreement to reduce the Thompsons’
deficiencies was to pay DeCastro’s fees; instead, they claimed,
the lowered deficiencies had something to do with the Thompsons’
19Rina appealed from this denial. Unlike the Thompsons,
Rina had no settlement agreement with Sims and McWade. On June
13, 1995, Rina agreed to the entry of a stipulated decision in
the amounts originally determined in his statutory notice of
deficiency.
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