- 11 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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