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Shortly after respondent answered petitioners' petitions,
she transferred the cases to Appeals. The Appeals officer met
with petitioners' counsel in an effort to settle these cases.
The Appeals officer reviewed petitioners' documentation for their
claimed deductions and other items and requested additional
substantiation from petitioners in order to determine their
correct tax liability. Respondent, through her Appeals officer,
made changes to her positions and offered settlements regarding
those changes based on the documentation petitioners furnished at
the Appeals conference; however, the parties could not then reach
a mutually acceptable settlement. After these cases were
transferred back to District Counsel, respondent's counsel
requested additional documentation through informal discovery.
Upon review of this additional documentation and a conference
between the parties, respondent was able to settle these cases
shortly over 1 year after issuing her notices of deficiency and
within 11 months of answering petitioners' petition.
Petitioners argue that respondent did not have a reasonable
basis in either fact or law primarily because her revenue agent
"employed poor audit procedures, made substantial erroneous
conclusions of fact and law, made arbitrary adjustments and
concocted corruptions of fact and law." Petitioners also argue
that respondent's agents did not contact petitioners at various
times during the review of their audit or during the interval
between the issuance of the revised RAR on June 28, 1993, and the
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