Jerry and Patricia A. Dixon, et al. - Page 82

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               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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