- 50 -
Respondent asserted that the new agreement was unauthorized and
had no legal basis. If respondent’s motion had been granted, the
Thompsons’ deficiencies would have been zero for taxable year
1979, $34,425 for 1980, and $30,000 for 1981.
On August 26, 1992, this Court granted DeCastro’s motions
for entry of decision in the Thompson cases, thus holding
respondent to the pretrial concessions made by Sims and McWade in
the new agreement:
Year Deficiency Additions to Tax
1979 --- ---
1980 $15,000 ---
1981 15,000 ---
The Tax Court’s decision for 1981 also relieved the Thompsons of
the non-Kersting late filing addition of $4,934.32 under section
6651(a). That addition was the only non-Kersting issue in the
Thompsons’ docketed cases.
Respondent did not appeal the decisions entered by the Court
with respect to the cases of the Thompsons and the Cravenses.23
23The Cravenses, who were not represented by counsel after
Seery’s withdrawal, had agreed with McWade to deficiencies of
$9,782.16 for their taxable years 1979 and 1980, a reduction of
only about 6 percent from the originally determined deficiencies
of $10,401.45. This settlement was less favorable to them
percentagewise than the generally available modified 7-percent
reduction settlement offer and did not include the “burnout”
feature. On Aug. 25, 1992, this Court entered a decision
reflecting the Cravens settlement amounts, but the decision
included the stipulation that certain advance payments made by
the Cravenses had not yet been taken into account. Late in
(continued...)
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