James E. Blasius and Mary Jo Blasius, et al. - Page 5

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          History of the Consolidated Cases                                           
               By notices of deficiency dated December 29 and 31, 2000 (the           
          notices of deficiency), respondent determined deficiencies in the           
          Federal income taxes of petitioners for the audit years.                    
          Explanations included with the notices of deficiency show                   
          adjustments to petitioners’ incomes resulting from changes in the           
          treatment of items of ACC passed through to Blasius and Balan on            
          account of their status as shareholders of ACC.  Respondent                 
          required the capitalization of certain costs incurred (and                  
          deducted) by ACC in connection with (1) “Loan Origination/                  
          Acquisition”, (2) “Offering Expenses”, and (3) “Professional                
          Fees”.                                                                      
               On March 30, 2001, petitions were filed in the cases (the              
          petitions), and, on May 21, 2001, respondent answered the                   
          petitions denying all assignments of error.                                 
               On January 9, 2002, the Court notified the parties that the            
          cases were set for trial at the trial session of the Court                  
          commencing June 10, 2002, in Detroit, Michigan.                             
               On March 14, 2002, attorney Oksana O. Xenos, on behalf of              
          all petitioners, wrote a letter to Eric R. Skinner, one of                  
          respondent’s counsel in this case.  In that letter, Ms. Xenos               
          requested that, in light of respondent’s position regarding the             
          deductibility of the types of costs at issue in the consolidated            
          cases, as stated in Announcement 2002-9, 2002-1 C.B. 536, issued            






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