- 100 -
Director's Office, requesting that the latter process a refund to
the Thompsons in the amount of $30,000.47
E. The Cravens Settlement
By letter dated September 29, 1986, Mr. Seery informed
Mr. Cravens of the terms of the modified 7-percent settlement
offer. On October 28, 1986, Mr. McWade disseminated the modified
7-percent settlement offer by form letter mailed to all known
Kersting program participants, including the Cravenses.48
Considering the nature and purpose of the form letter, it appears
that issuance of the letter to the Cravenses, who had already
been designated test case petitioners, was inadvertent.
On October 15, 1986, Mr. Cravens wrote to Mr. Seery asking
him to explain how the proposed settlement offer affected him and
to give him a recommendation. By letter dated October 23, 1986,
Mr. Seery advised Mr. Cravens to consult a tax preparer or
accountant because the offer was complicated in its application
to his case. Mr. Seery also noted that Mr. Cravens could take
advantage of the unlimited deduction for personal interest in
effect for 1986 by paying the liability in full in 1986 whether
or not he settled his case.49
47 The full text of Mr. McWade's memorandum is set forth
infra p. 137.
48 Mr. McWade's letter included a statement that the
modified 7-percent settlement offer would be withdrawn on
Dec. 31, 1986.
49 See supra note 44 regarding the Thompsons' interest
payment.
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