Jerry and Patricia A. Dixon, et al. - Page 42

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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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