- 99 - particular, Mr. McWade agreed to reduce the Thompsons' deficiencies in an amount sufficient to compensate them for the cost of having an attorney represent them at the trial of the test cases. Mr. DeCastro estimated that his legal fees for representing the Thompsons at the trial of the test cases would be approximately $60,000. Under the revised settlement agreement, the Thompsons' tax deficiencies were reduced to the following: Year Deficiency Additions to Tax 1979 --- --- 1980 $15,000 --- 1981 15,000 --- By reason of the Thompsons' having previously remitted $121,770 to the Internal Revenue Service for the taxable years 1979, 1980, and 1981, Mr. DeCastro and Mr. McWade calculated that the above- described reductions of the Thompsons' deficiencies would generate refunds of tax and interest to the Thompsons of approximately $60,000. Mr. DeCastro and Mr. McWade understood that the refunds generated by the reduced deficiencies would be used for the purpose of paying the Thompsons' attorney's fees to Mr. DeCastro. Although Mr. McWade and Mr. DeCastro agreed to revise the Thompson settlement in this manner before the trial of the test cases, the first written confirmation of their agreement appears after the trial, in the form of an April 10, 1989, memorandum from Mr. McWade to Tom Stevens (Mr. Stevens), Chief of Special Procedures in the Collection Division of the Honolulu DistrictPage: Previous 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 Next
Last modified: May 25, 2011