- 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.Page: Previous 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 Next
Last modified: May 25, 2011