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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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