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Court of Appeals mandated that “terms equivalent to those
provided in the settlement agreement” between the IRS and test
case petitioners John R. and Maydee Thompson (the Thompsons) be
extended to test case petitioners and all other taxpayers
properly before that court. Dixon v. Commissioner, 316 F.3d at
1047. It left to this Court’s “discretion the fashioning of such
judgments which, to the extent possible and practicable, should
put these taxpayers in the same position as provided for in the
Thompson settlement.” Id. n.11.
Petitioners primarily ground their motion for
reconsideration of Dixon VI, regarding the sanction to be imposed
on respondent, on allegations that respondent engaged in attempts
at a continued coverup of the fraud of respondent’s attorneys and
that this Court did not properly address that alleged continued
misconduct in Dixon VI.3 Petitioners ask the Court to reopen the
record in Dixon VI and impose additional sanctions on respondent
for respondent’s alleged continued misconduct. Because the Court
3Petitioners in their motion also ask us to change two
holdings of our Dixon VI opinion, our handling of the Thompsons’
sec. 6651(a) late-filing addition, and the cutoff date of
deficiency interest accruals against Kersting project
petitioners, described infra in text following note 9 as items
(3) and (4). Petitioners made their arguments on these issues in
their opening brief, and Dixon VI adequately addresses them.
Consequently, we decline to change our handling of the 1981 late-
filing addition or the cutoff date on the deficiency interest
accruals. See Estate of Quick v. Commissioner, 110 T.C. 440, 441
(1998).
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Last modified: May 25, 2011