George N. and Maggie Ahmaogak - Page 5

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               On March 29, 1995, respondent received an amended 1989                 
          Federal income tax return from petitioners.  The amended return             
          has not been included in the record, but apparently the                     
          deductions previously claimed and disallowed were increased,                
          other deductions not claimed on the original return were claimed,           
          and petitioners reported an income tax liability on the amended             
          return that was less than the income tax liability reported on              
          the original return.  We cannot tell whether or how the amended             
          return was processed.                                                       
               By the time the amended return was filed, petitioners and              
          other similarly situated taxpayers had cases pending in this                
          Court in which they disputed the Commissioner’s disallowances of            
          deductions similar to the deductions that gave rise to the                  
          determination of petitioners’ 1989 deficiency.  Furthermore,                
          legislation had been proposed that would have partially or fully            
          allowed for the types of deductions in dispute in the Tax Court             
          cases.  These cases were held in suspense for several years                 
          pending enactment of the legislation; however, the proposed                 
          legislation was never enacted.  The Tax Court cases were resolved           
          by agreement during 2000 after further settlement negotiations              
          with the Commissioner’s Appeals Office (the settlement position).           
               The settlement position was applied to petitioners’ 1990               
          year, which apparently had been examined before that time.  As a            








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