Jerry and Patricia A. Dixon, et al. - Page 89

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          denied their motions to intervene, and Izen and Sticht filed                
          notices of appeal.                                                          
               I.   Implementation and Effects of the                                 
                    Final Thompson Settlement                                         
               This Court’s August 1992 decisions enforcing the final                 
          Thompson settlement had a number of financial consequences.  The            
          Court’s decisions not only reduced the Thompsons’ deficiencies;             
          it also reduced the interest that had accrued on those                      
          deficiencies.  In December 1986 and in January 1987, the                    
          Thompsons had paid $59,545 of interest on their originally                  
          settled deficiencies of $34,425 for 1980 and $30,000 for 1981.              
          Because the Court’s decisions giving effect to the new settlement           
          agreement resulted in deficiencies of only $15,000 for each of              
          1980 and 1981, the interest that had accrued on those                       
          deficiencies before the Thompsons made their interest payments              
          was much less than $59,545.  Instead, as of December 31, 1986,              
          the interest accruals on the $15,000 deficiencies for 1980 and              
          for 1981 amounted to only $15,370.73 and $12,135.31,                        
          respectively.  As a result, the Thompsons’ aggregate payments of            
          $59,545 in December 1986-February 1987 were more than sufficient            
          to cover their total deficiencies and interest as eventually                
          reduced by the final Thompson settlement.                                   
               In January 1993, respondent made new assessments against the           
          Thompsons for 1980 and 1981 that were based upon the decisions              






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