Tate & Lyle, Inc. and Subsidiaries - Page 7

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          petition on October 21, 1994, including therein a general                   
          admission that the computation of petitioner's general business             
          credit is dependent upon the resolution of the substantive issues           
          in dispute.                                                                 
               By notice dated January 13, 1995, this case was calendared             
          for trial to be held in Washington, D.C., on June 19, 1995.  In             
          late February 1995, respondent discovered that she may have erred           
          in allowing petitioner a general business credit for the taxable            
          period ended September 30, 1990.5  Counsel for respondent first             
          mentioned the matter of the possible error in the computation of            
          petitioner's general business credit for the taxable period ended           
          September 30, 1990, in a letter to petitioner's counsel dated               
          March 22, 1995.                                                             
          On March 27, 1995, the parties filed a Joint Motion for                     
          Continuance stating that one of the issues in dispute would be              
          resolved consistent with the Court's final decision in docket No.           
          740-92 (Tate & Lyle, Inc. v. Commissioner, 103 T.C. 656 (1994)),            
          and that the parties desired additional time to attempt to settle           
          the remaining issues without a trial.  The Joint Motion for                 
          Continuance contains no mention of the general business credit              
          issue.  The parties' motion was granted on March 29, 1995.                  



          5  Respondent concedes that she was in possession of all the                
          information necessary to properly compute petitioner's general              
          business credit at the time that she issued the notice of                   
          deficiency in this case.                                                    



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