- 99 - denominator of $79,294 (the 1979-1981 tax deficiencies the Thompsons would have paid absent the settlement). D. Other Benefits Relating to the Thompsons’ 1981 Tax Year 1. Elimination of the Thompsons’ Late Filing (Non-Kersting) Addition for 1981 Petitioners maintain that the denominator of the settlement fraction should be increased by $4,934.32, representing the late filing addition in the Thompsons’ statutory notice for 1981 that they would have had to pay absent the settlement of their 1979- 1981 tax years. We disagree. Respondent’s proposed application of non-Kersting penalties and additions was specific to individual taxpayers, unlike the Kersting-related deficiencies and additions for which all affected taxpayers are liable. For that reason, we believe it is appropriate to limit the benefit of this aspect of the Thompson settlement (relief from liability for non-Kersting additions) to those affected taxpayers who, like the Thompsons, were subject to non-Kersting additions. We therefore deal with this aspect of the Thompson settlement separately from our determination of the percentage reduction in Kersting deficiencies that will apply to all affected taxpayers. See infra Part II.G.1.Page: Previous 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 Next
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