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to tax and for the elimination of the increased interest rate
under section 6621(c) for 1981. The burnout would also apply so
as to combine the agreed deficiencies for the years 1979 and 1980
in the year 1980. During this trip, DeCastro and McWade also
discussed the Bauspar program in which the Thompsons were
involved.
On December 23, 1986, McWade signed and sent DeCastro
stipulated decision documents in the Thompsons’ cases. The
transmittal letter stated that:
As previously indicated, the Decision documents
in John R. and Maydee Thompson will not be filed with
the Court until the Decision becomes final in the test
cases. In the interim, the Thompsons can make an
advance payment, as discussed at our conference, and
stop the accrual of any additional liability for
interest.
On December 30, 1986, DeCastro signed and returned to McWade the
executed decision documents agreeing to the reduced deficiencies.
Neither McWade nor Sims communicated the terms or existence of
the Thompsons’ settlement to their superiors.
The result of the pending settlement upon the Thompsons’ tax
liabilities would have been as follows:
Income Determined Proposed Percentage
Year Adjustment Deficiency Settlement Reduction
1979 $39,477 $18,161 ---
1980 72,840 24,838 $34,425
Total 42,999 34,425 20
1981 80,782 36,295 30,000 17
All years total 79,294 64,425 18.8
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