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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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