Jerry and Patricia A. Dixon, et al. - Page 52

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          Bauspar participants through the Kersting project.  Respondent’s            
          identification of Bauspar participants appears instead to have              
          been a “hit or miss” proposition; although respondent has                   
          disallowed some Bauspar deductions claimed by a few Kersting                
          project petitioners, those disallowances have been sporadic.                
               Because the Bauspar program was not included in respondent’s           
          Kersting project, we refer to interest deductions claimed under             
          the Bauspar program as Bauspar deductions rather than Kersting              
          deductions.                                                                 
               C.   Respondent’s Project Settlement Offer                             
               Between 1982 and 1988, respondent had in effect an official            
          settlement offer for the Kersting project.  In general, the offer           
          permitted participants in the Kersting programs to resolve their            
          cases by agreeing to pay income tax deficiencies that averaged 7            
          percent less than those determined in their deficiency notices.             
          The offer also released participants from negligence additions              
          and increased interest.                                                     
               By September 1986, respondent’s counsel had agreed to modify           
          the 7-percent reduction settlement offer to incorporate a new               
          feature, called the “burnout”, that would apply in cases                    
          involving more than one taxable year.  Under this procedure, the            
          interest on a taxpayer’s total unpaid deficiencies for the first            
          and second years of tax liability would not begin to accrue until           
          the return due date for the second year.  The burnout thus                  





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