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petitioners had paid for the years 1981 through 1985 -- including
the $130,836 that petitioners had paid on December 27, 1988.
On May 2, 1995, petitioners and respondent submitted to the
Court an agreed and signed decision document in docket No.
11904-88, involving petitioners’ Federal income tax liability for
1982, in which petitioners agreed to a tax deficiency for that
year of $44,693.
On April 26, 1995, one of respondent’s Appeals officers
wrote a letter to petitioners to explain the allocation by
respondent of the total $130,836 in payments that had been
received from petitioners on December 27, 1988. In that letter,
a misleading statement was made by respondent’s Appeals officer
relating to petitioners’ Federal income tax liabilities that
There remains no balance on the 1984 account, but each
of the other years show a balance in your favor which
will be refunded when this matter is closed.
At a Court hearing in petitioners’ case at docket No. 27394-
86 in New York City on December 9, 1997, the parties orally
settled issues relating to petitioners’ investment in White Rim
for 1980 and 1981, and the parties filed their stipulation of
settled issues therein on December 9, 1999.
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Last modified: May 25, 2011