- 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
Last modified: May 25, 2011