Jerry and Patricia A. Dixon, et al - Page 302




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               On December 30, 1986, Mr. Thompson sent a letter to                    
          Mr. McWade enclosing checks for $34,000 and $25,545 that were               
          intended as payments of interest on the Thompsons' tax                      
          liabilities for the taxable years 1980 and 1981, respectively.44            
               2.   First Revision of Thompson Settlement                             
               On January 27, 1987, Mr. Huestis sent a letter to                      
          Mr. DeCastro stating that Mr. Thompson did not understand the               
          terms of his settlement.  On February 3, 1987, Mr. DeCastro                 
          responded to Mr. Huestis as follows:                                        
               Dear Sam:                                                              
                    Thanks for your letter of January 27, 1987                        
               indicating questions which Jack Thompson has regarding                 
               the proposed settlement.  I will respond in the order                  
               of your questions:                                                     
                    1.   The only years in dispute are 1979, 1980 and                 
                         1981.                                                        
                    2.  For each year, the amounts claimed due by the                 
               I.R.S. by category are:                                                
                              1979      1980      1981     Total                      
               Tax deficiency  $18,161   $24,838   $36,295   $79,294                  
               Penalty             908     1,242    19,757    21,907                  
               Interest         19,977    24,838    27,976    72,791                  
               39,046    50,918    84,028   173,992                                   
                    3.  By the terms of the proposed settlement, the                  
               following amounts are due to be paid by Jack:                          




          44  Many Kersting program participants, like the Thompsons,                 
          made interest payments on or immediately before Dec. 31, 1986,              
          in order take advantage of the full deductibility of interest               
          in 1986.  The deductibility of payments of personal interest was            
          subject to phase-out for taxable years beginning after Dec. 31,             
          1986, pursuant to TRA sec. 511(b), 100 Stat. 2246.                          

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