- 66 - 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.Page: Previous 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 Next
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