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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
refund.
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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