Jerry and Patricia A. Dixon, et al. - Page 113

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               In sum, this Court has determined the terms of the Thompson            
          settlement.  Our decisions in these cases will apply those terms            
          to test case and nontest case petitioners alike.  Subject to the            
          review of the Court of Appeals, our opinion and decisions will              
          provide the template for the disposition of the more than 1,300             
          pending cases in the Kersting project.                                      
               The thoughts underlying the foregoing comments have informed           
          our effort not only to determine and apply the terms of the                 
          Thompson settlement, but also our effort to put petitioners, to             
          the extent possible and practicable, in positions similar to that           
          provided by the Thompson settlement.  Although it may be                    
          impossible to put petitioners in the same position, financial or            
          otherwise, the Thompsons were in 15 to 20 years ago, we observe             
          that the Code provisions for interest on deficiencies and                   
          overpayments,38 in which are embedded the time value of money               
          principles that underlie all financial planning,39 provide the              
          only available appropriate means of approximating the desired               
          equivalence.40                                                              

          38Secs. 6601, 6611.                                                         
          39See generally, e.g., Brealey & Myers, Principles of                       
          Corporate Finance (7th ed. 2003).                                           
          40Gokhale & Smetters, “Measuring Social Security’s Financial                
          Outlook within an Aging Society”, Daedalus 91-92 n.2 (Winter                
          2006), comment that discounting to present value, an operation              
          integral to giving effect to the time value of money, makes it              
          possible “to place dollars accruing at different points in time             
                                                             (continued...)           




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