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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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