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In arguing that the 1986 loans were modified after
December 31, 1986, petitioners stipulate that there is no
written agreement or other document evidencing a renewal,
renegotiation, modification, or extension of the loans.
Petitioners maintain that the loans were modified by the
"regular course of dealing" between petitioner and the
plan. Specifically, petitioners argue that "Petitioner's
longstanding failure to make required quarterly payments on
the notes (and the plan's failure to enforce such payments)
amounted to a revision or modification of the terms of the
underlying obligations."
Petitioners cite Tech. Adv. Mem. 93-44-001
(November 5, 1993) (the TAM) to support their position
that the plan's failure to demand payment constituted a
modification of the terms of the notes. We have previously
noted that a technical advice memorandum is merely a ruling
given to a specific taxpayer based upon the taxpayer's
specific facts and is not a ruling of general application.
See Golden Belt Tel. Association, Inc. v. Commissioner, 108
T.C. 498, 506 (1997). It does not constitute authority and
should not be cited as precedent. See sec. 6110(j)(3);
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