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Respondent’s facile concession gives us occasion to observe
that the Court will address the matter of attorney’s fees for
petitioners’ prosecution of these cases on appeal, as well as
petitioners’ attorney’s fees for the conduct of the postmandate
evidentiary hearing, in separate opinions and orders.
III. Interest on Deficiencies and Overpayments
Respondent has conceded that the accrual of interest on
taxpayer deficiencies ultimately determined by this Court should
be tolled as of June 1992, in accordance with the then Chief
Counsel’s public announcement on January 21, 2003. Petitioners,
however, maintain that the accrual of interest on any
deficiencies that remain after application of the Thompson
settlement should be halted as of December 31, 1986--the date by
which, petitioners maintain, the fraudulent McWade-DeCastro
agreement was first entered into.
The protracted nature of these proceedings has exaggerated
the impact of interest upon amounts that are owed by (or owed to)
the affected taxpayers. Informed by this realization, at a
status conference held in these cases on August 19, 2003, the
Court asked respondent to compare the fiscal consequences of
characterizing the Thompson settlement as (i) a 20-percent
reduction in the deficiencies determined by respondent, (ii) a
62-percent reduction, or (iii) an 80-percent reduction, with
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