- 14 -- 14 - (7th Cir. 1988), affg. T.C. Memo. 1987-52; Sokol v. Commissioner, 92 T.C. 760, 765 (1989). We also note that petitioners ultimately agreed that they were wrong with respect to their claim for 70.67 percent of the dollar amount of these adjustments (i.e., the Stipulation reflects the fact that petitioners were not allowed to deduct $64,843 of the $91,755 amount in dispute (21,025 + 7,334 + 63,396)). It is also hard to believe that petitioners neither received the Form W-2 from EP Management Services, Inc., nor knew that Mr. Beecroft had received $21,025 in wages that were not reported on their 1993 Form 1040. We find no persuasive evidence in the record to support petitioners' claim of overreaching by respondent's agents. To support their claim, petitioners submitted a May 15, 1996, letter from Mr. Lipton to respondent's counsel that petitioners allege reflects the terms of a settlement that they entered into with respondent on May 15, 1996. Petitioners allege that respondent backed out of this settlement in an attempt to increase the expenses that petitioners were incurring in litigating this matter and otherwise to force petitioners to settle this case for an inequitable amount. We are unpersuaded by this letter or by petitioners' claim with respect thereto. The record contains no evidence that this letter accurately reflects a settlement offer tendered to petitioners by respondent. As a point of fact, the record contains a letter from respondent's counsel to Mr. Lipton that was sent by facsimile during the morning of May 16, 1996.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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