- 4 -4 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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