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By notice dated August 12, 1998, the Court calendered
petitioner’s case for trial on November 2, 1998. Early in
October 1998, petitioner and respondent entered into settlement
negotiations. At the November 2, 1998, calendar, counsel for
respondent advised the Court that a basis for settlement had been
reached by the parties and requested 90 additional days to submit
the decision document. On December 24, 1998, respondent filed a
motion to restore the case to the general trial calendar,
reporting that a disagreement had arisen between the parties
regarding the tax computations for the income tax and net
operating losses.
Petitioner’s case was restored to the general calendar. By
Notice dated June 15, 1999, this case was calendared for trial at
the Court's trial session on September 7, 1999. The parties
resumed settlement negotiations. Counsel for respondent
determined that the hazards of litigation, as well as the cost of
trying the case, warranted a concession by respondent of a small
percentage of the losses attributable to the horse activity that
had been disallowed in the notice of deficiency for 1993 and 1994
and that had been disallowed for 1991 and 1992. Respondent also
determined that the hazards of litigation did not warrant any
concession by respondent of the loss attributable to the horse
activity that had been disallowed for 1990. Respondent’s
concession with respect to the small portion of the losses
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