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Respondent's Appeals Officer scheduled conferences for
February 4, 1988, and March 4, 1988. The Appeals Officer offered
petitioners the opportunity to set the date and time of the
conferences. Petitioners refused to attend any conferences or to
discuss the issues in this case.
In August 1988, petitioners were afforded the opportunity to
settle a portion of this case according to a uniform settlement
offer developed with regard to the Petro West tax litigation
project. Petitioners did not provide the Appeals Officer with
the documentation necessary to settle the case (i.e.,
verification of cash out-of-pocket expenses), nor did they
respond to the settlement offer.
On August 11, 1988, respondent sent petitioners a Branerton
letter, Branerton Corp. v. Commissioner, 61 T.C. 691 (1974), and
invited petitioners to meet for an informal discovery conference
on August 17, 1988. Respondent also suggested that petitioners
assemble documents and other records to establish that
petitioners were not liable for the adjustments set forth in the
notice of deficiency. The letter gave petitioners the option of
stipulating to be bound by the outcome of the lead case in the
Petro West tax litigation project. Petitioners failed to appear
for the August 17, 1988, meeting and also failed to provide any
of the requested documents.
Respondent, by formal discovery pursuant to Rule 72,
requested on August 17, 1988, and August 25, 1988, that
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