Lawrence S. and Myrna Ahmaogak - Page 4

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          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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