- 5 - 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 aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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