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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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