- 154 -
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6653(a) 6653(a)(1) 6651(a)(1)
1979 $4,508.00 $225.40 --- ---
1980 5,893.45 294.67 --- ---
The decisions entered in the Cravens cases did not
give effect to the settlement between Mr. Cravens and Mr. McWade.
Mr. Sims testified that he allowed the Court to enter decisions
in the Cravens cases for the full amount of the deficiencies as
computed by reference to the Court's opinion after the trial of
the test cases because he intended to honor his agreement with
the Cravenses by ensuring that a lower assessment would be
processed by the Appeals Office.
Mr. Sims spoke to Mr. Cravens about the difference between
the numbers in his settlement agreement and the larger numbers in
the Rule 155 computation and the decision documents. Mr. Sims
believed that Mr. Cravens understood that an assessment
consistent with his settlement would be made administratively.
However, when Messrs. Sims and McWade sent the Cravens cases to
the San Francisco Appeals Office for closing and assessment, they
did not request or instruct the Appeals Office to assess amounts
in accordance with the arrangement reached with Mr. Cravens in
December 1986.
Shortly after Messrs. Sanchez and Bakutes discovered the
Thompson settlement, Messrs. Sims and McWade disclosed the
Cravens settlement to them.
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