- 129 - 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, withPage: Previous 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131 132 133 134 135 136 Next
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