G. Dastgir and Mary A. Qureshi - Page 6

          petitioner’s investment and participation in the FoodSource                 
          program.7  Respondent determined that the FoodSource program was an         
          abusive tax shelter.                                                        
               Petitioner was one of a large number of persons nationwide who         
          had invested in the FoodSource program and claimed credits,                 
          deductions, and losses with respect thereto, which respondent               
          disallowed.  In order to resolve common issues, “test case                  
          petitioners” were selected among the persons whose credits,                 
          deductions, and losses had been disallowed by respondent and who            
          had petitioned this Court for a redetermination  of  that                   
          disallowance.  We rendered an opinion in the consolidated test              
          cases entitled Noonan v. Commissioner, T.C. Memo. 1986-449, affd.           
          without published opinion sub nom. Hillendahl v. Commissioner, 976          
          F.2d 737 (9th Cir. 1992).                                                   
               Subsequent to our decisions in Noonan and the conclusion of            
          the appeal thereof, on August 7, 1989, petitioners and respondent           
          entered into a closing agreement (Form 906) regarding the credits,          
          deductions, and losses petitioners claimed on their 1979, 1980,             
          1982, and 1983 tax returns with respect to petitioner’s investment          
          and participation in the FoodSource program.  In pertinent part,            
          the closing agreement states:                                               

               7    Petitioners claimed refunds for carrybacks to their               
          1979 through 1981 tax years, based upon the depreciation                    
          deductions, interest expense, and investment tax credit as a                
          result of petitioner’s purchase of the container.                           

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