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RAR relating to Simpson Financial with respondent's examination
division. A revised RAR for Simpson Financial was issued to
petitioners on June 28, 1993. The revised RAR conceded portions
of the revenue agent's adjustments to Simpson Financial's gross
receipts and cost of goods sold. The revised RAR stated that
Simpson Financial's proposed deficiency was $28,682, rather than
$55,844 as reflected on the previous RAR, and the additions to
Simpson Financial's tax were proportionately lowered.
Respondent mailed notices of deficiency to petitioners on
December 20, 1994, taking into account the adjustments in the
revised RAR. On March 20, 1995, petitioners filed their
respective petitions in this Court. After respondent answered
these petitions on April 20, 1995, she transferred the cases to
Appeals for settlement consideration.
On April 24, 1995, an Appeals officer mailed a letter to
petitioners' counsel suggesting that they discuss the cases on
May 17, 1995. By letter dated May 2, 1995, petitioners' counsel
requested a later date. The parties held a conference on
July 25, 1995, and petitioners provided documentation to the
Appeals officer, which was in addition to other documentation
provided earlier to the revenue agent during her examination.
Based upon this new documentation, the Appeals officer wrote
petitioners' counsel on July 27, 1995, to settle various issues.
While the cases were still within Appeals, Appeals asked the
examination division to audit the NOL reported for Simpson
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