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involved as a test case, the documents are being held in our
files, and will be signed and filed with the Court when the test
case litigation has been completed." The revised decision
documents prepared by Mr. McWade set forth the Thompsons' tax
liabilities as follows:
Year Deficiency Additions to Tax
1979 --- ---
1980 $33,000 ---
1981 30,000 ---
On August 5, 1987, Mr. DeCastro sent copies of the proposed
decision documents to the Thompsons.
3. Second Revision of Thompson Settlement
Before the trial of the test cases, Mr. DeCastro informed
Mr. McWade that the Thompsons were having financial difficulties
and that he did not think that it was fair to require the
Thompsons to remain as test case petitioners. Mr. DeCastro
expressed concern to Mr. McWade about the amount of legal fees
the Thompsons would incur as test case petitioners and informed
Mr. McWade that he would attempt to have the Thompsons removed
from the list of test cases. Mr. McWade told Mr. DeCastro that
he did not want the Thompsons to be removed as test case
petitioners because he did not want to change the test cases so
close to trial. Mr. DeCastro thought that Mr. McWade's desire to
retain the Thompsons on the list of test cases was caused by
administrative or technical concerns.
Mr. DeCastro and Mr. McWade resolved their respective
concerns by further modifying the Thompson settlement. In
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