- 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.
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