- 186 -
As we understand petitioner's position, he asks us to infer
from the foregoing stipulation the existence of a policy by the
Service of applying Rev. Rul. 87-89, supra, on a prospective
basis only. We decline to draw any such inference. We also note
that there are other inferences that may be drawn from the par-
ties' stipulation. For example, there may have been other cases
pending in respondent's examination division and/or in the courts
of which the offices of respondent specified in that stipulation
were aware, but as to which the parties there involved reached
agreement, and therefore such cases were no longer unagreed or
docketed.
With respect to petitioner's third contention (viz., respon-
dent's examining agent who proposed the deficiencies relating to
the Bank transactions bore personal animosity toward petitioner),
the record does not establish that that agent harbored any per-
sonal animosity toward petitioner.140 Even assuming arguendo that
such animosity were shown by the record, petitioner has not
demonstrated that it was the basis for the determinations in the
notices.141 While the agent admitted in his testimony that he
140 We are not persuaded by the examining agent's acknowledgment
at trial that he previously had indicated that "rich people from
Hong Kong undermine the U.S. tax system" that that agent harbored
personal animosity toward petitioner.
141 We note that petitioner does not suggest that personal ani-
mosity played a role in the determination of the deficiencies at
issue in Fu Inv. Co. v. Commissioner, docket No. 13306-92. The
(continued...)
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