- 4 -
2000, and the deficiencies, an addition to tax, and interest were
assessed on May 29, 2000.
The examination, Appeals consideration, and litigation
phases for the years 1988, 1989, and 1991 progressed in a manner
similar to that for the years 1986 and 1987. For each of these
later years, deductions similar to the those claimed and
disallowed for 1986 and 1987 were also claimed and disallowed.
However, by the time the examination of 1991 was completed,
petitioners had decided to forgo Appeals consideration and
proceed with a test case before this Court.
As of July 28, 1994, petitioners had three cases docketed in
this Court (the docketed cases).4 The docketed cases were
consolidated with other cases involving similarly situated
taxpayers. At petitioners’ request, the docketed cases were held
in suspense to allow for the enactment of proposed Federal
legislation that specifically addressed the types of deductions
in dispute in those cases. Although the proposed legislation was
never enacted, petitioners and respondent agreed to a settlement
in each of the docketed cases, the terms of which are consistent
with the relief contemplated by the proposed legislation.
4 Docket No. 20784-91, filed Sept. 16, 1991, involving 1986
and 1987; docket No. 23983-92, filed Oct. 27, 1992, involving
1988 and 1989; and docket No. 13503-94, filed July 28, 1994,
involving 1991.
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