Jerry and Patricia A. Dixon, et al - Page 58




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          negligence, failure to file a timely return, and the increased              
          rate of interest for substantial understatement of income tax               
          attributable to tax-motivated transactions.                                 
          D.   Disclosure of Thompson Settlement                                      
               On March 13, 1992, the Court entered decisions pursuant to             
          its Dixon II opinion in each of the test cases.  The Court                  
          entered decisions in the Thompson cases consistent with the                 
          notices of deficiency issued to the Thompsons as follows:                   
                 Additions to Tax                                                     
          Sec.      Sec.        Sec.                                                  
           Year         Deficiency        6653(a)  6653(a)(1)  6651(a)(1)             
          1979     $18,161.00         $908       ---         ---                      
          1980          24,838.00          ---       ---         ---                  
          1981          36,294.52          ---    $1,958.28   $4,934.32               

          The decisions provided that the Thompsons were liable for 50                
          percent of the interest due on the deficiency for 1981 pursuant             
          to section 6653(a)(2) as well as increased interest pursuant to             
          section 6621(c).                                                            
               By letter dated April 23, 1992, Mr. McWade forwarded to                
          Mr. DeCastro waiver agreements which, if executed by                        
          Mr. DeCastro, would authorize the Internal Revenue Service to               
          enter assessments against the Thompsons before expiration of the            
          90-day appeal period prescribed by section 7481.  Mr. McWade's              
          letter stated that, on the basis of the Thompsons' earlier                  
          payments, there would be due a refund of approximately $56,873.03           






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