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project settlement offer was extended to them, but they do not
claim to have accepted the offer timely, so they effectively
rejected it.
In December 1988, the Miller cases were disposed of by
settlement agreement between the taxpayers and respondent.8
This Court entered decisions based upon those settlements on
December 22, 1988. The settlement provided that the taxpayers in
the Miller cases were liable for the addition to tax under
section 6659 for valuation overstatement, but not for the
additions to tax under sections 6661 and 6653(a). The increased
interest under section 6621(c), premised solely upon Miller's
interest in the recyclers for the taxable years at issue, was not
applicable because Miller made payments prior to December 31,
1984, so no interest accrued after that time. Respondent did not
notify petitioners or any other taxpayers of the disposition of
the Miller cases. Estate of Satin v. Commissioner, supra; Fisher
v. Commissioner, supra.
Petitioners argue that they are similarly situated to
Miller, the taxpayer in the Miller cases, and that pursuant to
the principle of "equality" they are therefore entitled to the
same settlement agreement executed by respondent and Miller in
8 Although it is not otherwise a part of the record in these
cases, respondent attached copies of the Miller closing agreement
and disclosure waiver to her objection to petitioners' motion for
leave, and petitioners do not dispute the accuracy of the
document.
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