- 30 - 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.Page: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
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