Jerry and Patricia A. Dixon, et al. - Page 103

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               On January 21, 2003, respondent’s then Chief Counsel,                  
          referring to Dixon V, publicly announced:  “We will * * * assure            
          that no interest is charged on deficiencies for the period of the           
          appeals to the Ninth Circuit.”30                                            
               On February 3, 2003, Deborah Butler, respondent’s Associate            
          Chief Counsel for Procedure and Administration, issued a Chief              
          Counsel notice (CC-2003-008), reminding all Chief Counsel                   
          attorneys, in light of the opinion of the Court of Appeals in               
          Dixon V, “to adhere to the highest ethical standards when                   
          performing their duties, including when representing the IRS                
          before the Tax Court.”                                                      
               On March 14, 2003, the Court of Appeals issued orders                  
          remanding to the Tax Court for further proceedings consistent               
          with the opinion in Dixon V the nontest cases that had been                 
          appealed pursuant to their certification for interlocutory                  
          appeal.  On April 23, 2003, the Court of Appeals issued its                 
          mandates with respect to the test cases in accordance with Dixon            
          V.                                                                          
               D.   Proceedings Following Remand                                      
               On April 30, 2003, respondent filed a motion for a status              
          conference regarding disposition on remand of the test cases and            
          a group of related nontest cases.  On May 1, 2003, this Court               


          30The original decisions in Dixon II were entered Mar. 13,                  
          1992; the notices of appeal were filed May 14, 1992; the 90-day             
          appeal period would have expired June 11, 1992.                             




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