Simpson Financial Services, Inc. - Page 6

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          Financial's 1987 taxable year.  Appeals made this request due to            
          the disallowed loss carryforward from 1987 to 1988.                         
               Settlement negotiations between the parties continued                  
          through September 11, 1995, when it became apparent to the                  
          parties that they would be unable to reach a mutually agreeable             
          settlement.  Petitioners' counsel sent the Appeals officer a                
          letter requesting the case be transferred back to District                  
          Counsel, citing his objection to the Appeals officer's continued            
          demands for additional documentation.  On September 15, 1995,               
          Appeals referred the cases back to District Counsel for trial               
          preparation.                                                                
               Shortly thereafter, District Counsel was notified by the               
          examination division that Simpson Financial's 1987 Federal income           
          tax return would not be audited.  Petitioners and District                  
          Counsel held a conference on December 14, 1995, to discuss the              
          cases in preparation for trial.  At that conference, the parties            
          reviewed various documentation that petitioners provided in                 
          response to District Counsel's informal discovery request.  While           
          some of this documentation had been provided earlier by                     
          petitioners to respondent either at the audit level or later at             
          the Appeals level, petitioners furnished additional documentation           
          that had not previously been provided to respondent.  The parties           
          settled all issues raised by the notice of deficiency issued to             
          Simpson Financial, including the NOL carryforward, which                    
          respondent conceded.  Respondent conceded the NOL issue after the           




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