- 20 -                                         
               The presence of an admission, express or implied,                      
               serves as direct proof that the taxpayer was not                       
               contesting liability.  But absence of an admission,                    
               while not conclusive proof of a contest, certainly                     
               leaves a gap in petitioner’s proof * * * [Id. at 654.]                 
               There are a number of court opinions involving a variety of            
          factual situations and the question of whether accrual basis                
          taxpayers' liabilities with regard to tax adjustments and the               
          related statutory interest should be regarded as sufficiently               
          settled, as fixed and definite, and whether the amounts thereof             
          were determinable with reasonable accuracy, or whether the                  
          taxpayers' liabilities therefor should be regarded as contingent            
          and contested.                                                              
               A number of courts have defined a contest narrowly and have            
          suggested that affirmative acts by taxpayers which establish                
          clearly the existence of the contest should be present in order             
          for the asserted tax liabilities to be regarded as contested.  In           
          Hollingsworth v. United States, 215 Ct. Cl. 328, 568 F.2d 192,              
          202-203 (1977), a dispute with a State agency, not with                     
          respondent, over a change in method of accounting and what was              
          regarded merely as a “naked suggestion” (not as an objection) by            
          the taxpayer to respondent that a proposed adjustment not be made           
          until a following year were treated as not rising to the level of           
          a contest with respondent over the related income tax deficiency            
          and interest.                                                               
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