David and Barbara Kincaid - Page 4




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          based on the outcome of the test cases were filed on March 14,              
          1994.                                                                       
               The Encoder decision became final on June 12, 1994.                    
          Respondent denied petitioners’ claim for their proportionate                
          share of credits on their 1982 return and for a carryback of                
          unused credit to their 1979 return.  On May 29, 1995, respondent            
          assessed tax against petitioners of $3,211 for 1979, and $9,400             
          for 1982, relating to petitioners' indirect investment in Encoder           
          through Signature.                                                          
          B.   Respondent's Notices of Deficiency for 1979 and 1982 and               
               Later Events                                                           
               Respondent mailed affected items notices of deficiency to              
          petitioners for 1979 on May 30, 1995, and for 1982 on June 5,               
          1995.  In them, respondent determined that petitioners were                 
          liable for the addition to tax for overvaluation under section              
          6659 relating to their share of the Signature/Encoder disallowed            
          credits in 1979 and 1982.  Petitioners filed a petition with this           
          Court on August 28, 1995, disputing the determinations (docket              
          No. 16805-95).  Respondent filed an answer on October 30, 1995.             
               On January 31, 1996, Patrick Wilcox (Wilcox), respondent's             
          Appeals officer, sent a letter to petitioners stating that it was           
          important to meet as soon as possible.  On February 2, 1996,                
          petitioners' daughter telephoned Wilcox to arrange a conference.            
          On February 3, 1996, petitioners wrote a letter to Wilcox stating           
          that they were ready to meet.                                               





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