- 15 - before January 1, 1987. See TRA sec. 511(b), 100 Stat. 2246. The payment was made with two checks, one of which, for $34,000, was originally dishonored. The Thompsons replaced the $34,000 check early in 1987.12 On June 15, 1987, pursuant to further negotiations, the Thompsons paid the total proposed deficiencies of $63,000, in order to halt further accrual of interest on the deficiencies.13 By June 1987, their payments to the Internal Revenue Service with respect to the taxable years 1979 through 1981 totaled $121,770. Shortly before trial of the test cases in this Court in January 1989, Messrs. McWade and DeCastro reached an oral agreement (the new agreement) in the Thompsons’ cases calling for reduction of the agreed deficiencies for 1979, 1980, and 1981 to zero, $15,000, and $15,000, respectively. The purpose of this reduction was to generate refunds to the Thompsons from the $121,770 they had previously paid toward satisfaction of the 12In March 1987, Mr. McWade agreed to reduce the combined deficiency of the Thompsons for 1979 and 1980 from $34,425 to $33,000, bringing the reduction in total deficiencies to approximately 20 percent. The record does not disclose why Mr. McWade agreed to that reduction, although similar 20-percent reduction settlements were later offered to the clients of Messrs. Chicoine and Hallett. Mr. DeCastro communicated this proposed reduction to his clients, but apparently he did not execute decision documents confirming the Thompsons’ acceptance of this lowered amount. 13The Thompsons paid this amount with a check for $63,000; respondent credited $775 to their taxable year 1988, a year not then before the Court. The balance of $62,225 was credited to their liabilities for their taxable year 1979.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011