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dated February 19, 1993, which the Thompsons endorsed to DeCastro
Law Corp.
The refund of $32,225 to the Thompsons was based upon the
conclusion that, as of December 30, 1986, when the Thompsons
first remitted a total of $59,545 as interest payments for the
years 1979, 1980, and 1981, the Thompsons' total tax liability
for those years, as reflected in the Court's decisions entered
on August 26, 1992, was approximately $57,500--comprising $30,000
in tax and $27,500 in interest. Accordingly, the Thompsons'
December 1986 remittance of $59,545 resulted in an overpayment
of approximately $2,045. In addition to this overpayment, on
June 17, 1987, the Thompsons had made an additional payment of
$62,225 towards their tax liability for 1979. The $32,225 refund
paid to the Thompsons on February 19, 1993, represents the
difference between the Thompsons' $62,225 payment and the $30,000
refund that the Thompsons had previously received in July 1989.
Following the receipt of the $32,225 refund, Mr. DeCastro
wrote to Mr. Dombrowski to complain that respondent had erred in
computing the amount of the Thompsons' overpayment. After
review of the matter, Mr. Dombrowski prepared a memorandum to
Mr. Bakutes dated September 17, 1993, requesting approval to
process an additional refund to the Thompsons of approximately
$32,000. Mr. Dombrowski stated that, in calculating the prior
refund of $32,225, respondent had erroneously treated the $62,225
payment that the Thompsons made in June 1987 as a cash bond
rather than an advance payment of tax. Viewing the $62,225
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