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of the Court’s opinion relating to the deductions and for leave
to amend their respective petitions in order to place the
deduction issue properly before the Court.
Petitioners at docket Nos. 7561-98, 7563-98, 7564-98, and
7567-98 seek to amend their petitions by adding the following
paragraph:
8. Petitioners are entitled to claim a deduction
for the foreign income taxes they paid to the State of
Israel in 1991 ($296,554) and 1992 ($704,450) pursuant
to Treasury Regulation �1.901-1 in the event any of the
paid taxes are not allowed as a credit under Sections
901-908.
Similarly, petitioners at docket Nos. 19356-98, 19357-98,
19358-98, and 19359-98 seek to amend their respective petitions
by adding the following paragraph:
8. Petitioners are entitled to claim a deduction
for the foreign income taxes they paid to the State of
Israel in 1994 ($291,695) pursuant to Treasury
Regulation �1.901-1 in the event any of the paid taxes
are not allowed as a credit under Sections 901-908.
On September 12, 2000, respondent filed notices of objection
to petitioners’ motions. Petitioners then responded thereto with
filings on September 26, 2000. Upon receipt of these
submissions, the Court directed by an order dated October 5,
2000, that the parties file memoranda of law addressing certain
procedural issues raised by the motions.
In the ensuing interval, on October 10, 2000, respondent
filed a motion for reconsideration asking the Court to clarify
its analysis of petitioners’ reporting on their Forms 1116,
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