International Multifoods Corporation and Affiliated Companies - Page 4

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               In his motion to sever issue, filed on July 19, 1996,                  
          respondent stated:  "At this time, respondent is hopeful that the           
          proposed regulations will be finalized during the beginning of              
          the 1997 calendar year."  On March 3, 1997, respondent filed a              
          status report, which indicated that the stock loss regulations              
          had not yet been finalized.  On March 5, 1997, we ordered                   
          respondent to file, on or before May 12, 1997, an additional                
          status report with respect to the finalization of these                     
               On March 13, 1997, petitioner filed a Motion for Court to              
          Decide Paty Loss Issue.  In its motion, petitioner stated that on           
          the basis of respondent's March 3, 1997, status report, "it does            
          not appear that there is any specific date by which the proposed            
          regulations are targeted to be issued as a Treasury Decision."              
          Petitioner also argued that despite respondent's acknowledgment             
          that the adoption of the proposed regulations in their current              
          form would decide the Paty stock loss issue in petitioner's                 
          favor, "Respondent continues to decline confessing error.  The              
          only purpose for not doing so is to preserve the ability to                 
          contest the Petitioner's treatment of the loss."  Petitioner                
          maintained that "The prejudice is compounded by the fact that the           
          Petitioner has not only paid the full amount of the determined              
          deficiencies and interest thereon in the present case, it has               
          overpaid the deficiencies and interest based upon the settlement            
          of other issues."  On April 29, 1997, respondent filed a Notice             

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