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B. No Procedural Defense to Determined Deficiencies
Petitioners have asserted a number of procedural defenses to
the determined deficiencies and adjustments, but none of these
defenses is well founded.
We do not consider persuasive, or even relevant, the fact
that respondent may have accepted without protest earlier filings
from the partnerships. It is well settled that the
Commissioner's prior determinations do not relieve a taxpayer of
its burden of proving error in the Commissioner's current
determination. Coors v. Commissioner, 60 T.C. 368, 406 (1973),
affd. 519 F.2d 1280 (10th Cir. 1975).
Petitioners also claim that statutory developments have
removed respondent's authority to disallow deductions for the
years at issue. They argue that Congress has instead provided a
different arrangement in section 448(d)(7). That provision was
enacted as part of the Tax Reform Act of 1986, Pub. L. 99-514,
sec. 801(a), 100 Stat. 2345. It requires a tax shelter to report
taxable income on the basis of a phased-in change from the cash
method to the accrual method, beginning in 1987. Petitioners
argue that they complied with this provision. They conclude that
respondent contravened this provision and acted without authority
in disallowing the partnerships' cash basis deduction of employee
leasing costs for years prior to 1987. Petitioners assume too
much. In enacting section 448(d)(7), Congress did not cancel the
threshold requirement that only substantive transactions will be
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