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On June 15, 1987, Mr. DeCastro sent a $63,000 cashier's
check "in partial payment of the total amount due" to the
Internal Revenue Service Center in Fresno, California, on behalf
of the Thompsons. The remittance was made with respect to the
Thompsons' three docketed cases and included a request that the
matter be referred to a problems resolution officer "so that we
can determine the balance due and conclude this matter." On
June 17, 1987, the Commissioner "transferred" $775 of the $63,000
payment to the Thompsons' account for 1988 and applied the
$62,225 balance to the Thompsons' account for 1979.46 As of June
1987, the Thompsons had paid a total of $121,770 towards their
tax liabilities (tax and interest) for the taxable years 1979,
1980, and 1981.
On July 10, 1987, Mr. DeCastro wrote to Mr. McWade
transmitting a Notice of Overdue Tax received by the Thompsons
with respect to their 1981 income tax liability. Mr. DeCastro
asked Mr. McWade to contact him regarding the notice and to send
him "copies of the decisions entered in this matter." On
July 24, 1987, Mr. McWade sent Mr. DeCastro copies of proposed
decision documents for the Thompson cases. Mr. McWade informed
Mr. DeCastro that "per our understanding, since the Thompsons are
46 The record does not reflect the basis for the
Commissioner's transfer of $775 of the payment to the Thompsons'
account for 1988. Because the 1988 tax year had not even started
on the date of the transfer, there can be no reasonable
explanation for the transfer; perhaps it was a typographical
error and was intended to refer to the taxable year 1978, which
Mr. Huestis had settled on the Thompsons' behalf.
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