Roger L. and Patricia A. Lavallee - Page 6

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            Petitioners failed to file a petition with this Court with                                
            respect to the notice of deficiency.                                                      
                  After respondent instituted collection procedures with                              
            respect to these deficiencies, petitioners retained Steven W.                             
            Conner, a certified public accountant in Orange Park, Florida.                            
            In January 1991, Mr. Conner filed amended Federal income tax                              
            returns for petitioners for 1985, 1986, and 1987.6  In Part II                            
            (Explanation of Changes to Income, Deductions, and Credits) of                            
            each amended return, Mr. Conner included the following statement:                         

                  Taxpayers' originally filed return was audited and                                  
                  changes requiring payment of additional tax were made.                              
                  The taxpayer [sic] was not able to contact the revenue                              
                  officer before the case was closed to contest the                                   
                  changes.  The taxpayers are long haul truckers.  The                                
                  changes on this amended return convert the audited                                  
                  numbers back to the return as filed.  The taxpayer                                  
                  believes the return was correct as filed.  * * *                                    

            In a letter dated March 25, 1991, respondent indicated that the                           
            claims in petitioners' amended returns would not be considered                            
            unless petitioners first paid the tax and then filed a claim for                          
                  On October 31, 1991, respondent received an Offer in                                
            Compromise (Form 656), prepared by Mr. Conner, with reference to                          
            petitioners' 1985, 1986, and 1987 Federal income tax liabilities.                         
            In an October 21, 1991, letter accompanying the Form 656, Mr.                             
            Conner explained that petitioners made the offer "because of                              

                  6The amended returns for 1986 and 1987 were filed on Jan. 3,                        
            1991, and the amended return for 1985 was filed on Jan. 14, 1991.                         

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