- 7 - petition on October 21, 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 January 13, 1995, this case was calendared for trial to be held in Washington, D.C., on June 19, 1995. In late February 1995, respondent discovered that she may have erred in allowing petitioner a general business credit for the taxable period ended September 30, 1990.5 Counsel for respondent first mentioned the matter of the possible error in the computation of petitioner's general business credit for the taxable period ended September 30, 1990, in a letter to petitioner's counsel dated March 22, 1995. On March 27, 1995, the parties filed a Joint Motion for Continuance stating that one of the 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)), and that the parties desired additional time to attempt to settle the remaining issues without a trial. The Joint Motion for Continuance contains no mention of the general business credit issue. The parties' motion was granted on March 29, 1995. 5 Respondent concedes that she was in possession of all the information necessary to properly compute petitioner's general business credit at the time that she issued the notice of deficiency in this case.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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