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petitioner's general business credit, it is clear from the
context that petitioner raised the issue as a purely
computational matter. Respondent filed her answer to the
petition on January 31, 1994, including therein a general
admission that the computation of petitioner's general business
credit is dependent upon the resolution of the substantive issues
in dispute.
By notice dated May 26, 1994, this case was calendared for
trial to be held in Washington, D.C., on October 31, 1994. On
June 30, 1994, the parties filed a Joint Motion for Continuance
stating that one of the central issues in dispute would be
resolved consistent with the Court's final decision in docket No.
740-92 (Tate & Lyle, Inc. v. Commissioner, 103 T.C. 656 (1994),
on appeal (3d Cir., May 9, 1995)), and that the parties desired
additional time to attempt to settle the remaining issues without
a trial. The parties' motion was granted on July 5, 1994.
By notice dated September 29, 1994, this case was again
calendared for trial to be held in Washington, D.C., on March 6,
1995. On February 3, 1995, the parties filed a Joint Motion for
Continuance along with a Stipulation of Settled Issues. In their
Joint Motion for Continuance, the parties reported that: (1)
although the Court had issued its opinion in docket No. 740-92,
Tate & Lyle, Inc. v. Commissioner, supra, respondent was
contemplating filing an appeal in the case; and (2) the parties
had reached a settlement with respect to all but one of the
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