- 32 - agreement they reached with Appeals Officers Johnson and Sinclair. During the negotiations, Mr. Deaton informed Appeals Officer Sinclair that petitioners would file their consolidated 1979 return using the hybrid method even though such return had initially been prepared on the cash method and the time for filing was near. Mr. Kown would not have agreed to adopt the hybrid method for the 1972 and 1973 years had he known that the IRS would object to its use for petitioners' returns filed for subsequent taxable years. In an attempt to memorialize his understanding of the agreement with Appeals Officers Johnson and Sinclair, Mr. Kown wrote them a letter on June 13, 1980, in which he outlined his understanding of the proposed resolution of the accounting method issue. Mr. Kown further stated that it was petitioners' understanding that their agreement with respect to such issue would be binding until Congress expressly prohibited the hybrid method of accounting by hospitals. Mr. Kown sent the letter prior to the time the stipulations regarding such issues were prepared and filed with the U.S. Tax Court. He did not receive a written response to his letter but he subsequently discussed it in a telephone conversation with Appeals Officer Sinclair. At such time, Appeals Officer Sinclair, while "making no promises", indicated that he thought that the hybrid method would continue to be followed unless a statutory change or a final controlling court decision required a different result.Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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