Jerry and Patricia A. Dixon, et al. - Page 67

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          change that reduced the deficiency for that year from $34,425 to            
          $33,000.  McWade later explained:  “It must have been I                     
          miscomputed something.”  With this modification of the                      
          settlement, the Thompsons’ aggregate deficiencies for 1979-1981             
          were reduced by 20.55 percent of the deficiencies originally                
          determined by respondent (i.e., from $79,294 to $63,000).                   
               On June 15, 1987, DeCastro sent a $63,000 cashier’s check              
          “in partial payment of the total amount due” to the Internal                
          Revenue Service Center in Fresno on behalf of the Thompsons.                
          Respondent received the payment of $63,000 on June 17, 1987, and            
          credited it to the Thompsons’ 1979 account as an advance payment,           
          less offset of a credit of $775 that was applied to their 1988              
          tax year.  Accordingly, by June 1987, the Thompsons’ payments to            
          the IRS with respect to the taxable years 1979-1981 totaled                 
          $121,770 ($62,225 as an advance payment of tax, and $59,545 as              
          interest).                                                                  
              D.   IRS Activity Regarding the Thompsons’                             
                    1983-85 Returns                                                   
               In the meantime, an employee of respondent at the Fresno               
          Service Center in California (with initials A.A.K.) prepared a              
          statutory notice of deficiency (subsequently dated March 17,                
          1987) disallowing $67,620 of Kersting deductions claimed on the             
          Thompsons’ 1983 income tax return.  Because the Thompsons had               
          little taxable income that year, the first whole year of Mr.                






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