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Dear Ken:
The following are my calculations of the refund
due the Thompsons:
1980 Deficiency: $15,000
Interest on Deficiency: 15,300 $30,300
(To 12-31-86)
1981 Deficiency: $15,000
Interest on Deficiency 12,150 27,150
Total Tax and Interest due to 12-31-86 $57,150
Amount Paid 12-31-86 ($25,545 plus $34,269) $59,814
Overpayment as of 12-31-86 2,664
Additional amount paid
on account 6-11-87 63,000
TOTAL OVERPAYMENT DUE TAXPAYER $65,664
Please calculate the interest due on the
overpayment and arrange to refund the balance due them
(less the $30,000 recently received).
Thanks for your cooperation.
On October 3, 1989, Mr. DeCastro sent the Thompsons a letter
reporting that Mr. McWade had confirmed that they were due a
large refund, plus interest, which would not be refunded until
the Court issued its opinion in the test cases. Mr. DeCastro
advised the Thompsons that, because the Internal Revenue Service
would be paying interest, he believed it was fair to add interest
to the Thompsons' bill.
On or about November 6, 1989, Mr. McWade received an undated
letter from Mr. Thompson which stated in pertinent part as
follows:
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