Jerry and Patricia A. Dixon, et al. - Page 77

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               Re: Jack and Maydee Thompson                                           
               Dear Ken:                                                              
                    Please confirm following is our agreement with                    
               respect to settlement of above taxpayer’s cases for                    
               open years:                                                            
                    We have agreed that the total taxes due for all                   
               the open years are $15,000 for 1980 and $15,000 for                    
               1981.                                                                  
                    Further, in the event a final decision in this                    
               case is more favorable they are to receive the benefit                 
               of such decision.                                                      
               Please sign below so I can have for my files.                          
          McWade signed the letter and returned it to DeCastro.                       
               On August 24, 1989, DeCastro wrote McWade requesting him to            
          arrange for the Thompsons to receive the balance of their refund.           
          McWade replied that the balance would not be released until the             
          Tax Court had issued its opinion, and DeCastro so informed the              
          Thompsons.  DeCastro told the Thompsons that, because the IRS               
          would be paying interest, he believed it was fair to add interest           
          to the Thompsons’ bill.                                                     
               On or about November 6, 1989, McWade received an undated               
          letter from Mr. Thompson, which stated in pertinent part as                 
          follows:                                                                    
               Dear McWade:                                                           
               There are some questions in mind that I feel you can                   
               help me answer.                                                        
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