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Conner's November 23, 1992, letter raised additional issues and
provided additional information. In his examination workpapers,
Revenue Agent Roberts stated that petitioners had adequately
substantiated the amounts of their Schedule C deductions as
listed in Mr. Conner's letter. However, Revenue Agent Roberts
also concluded that he lacked the authority to allow petitioners
to claim Schedule C deductions in excess of the greater of the
amounts originally reported on the returns for those years or the
amounts allowed by Office Auditor Barrow during her examination
of petitioners' returns.10 Revenue Agent Roberts then
transferred petitioners' case to respondent's Appeals Office for
a determination as to the total amount of Schedule C deductions
which petitioners were entitled to claim.
In a letter dated May 17, 1994, Appeals Officer Robert W.
Whittle advised Mr. Conner that he had scheduled a conference for
June 29, 1994, in Jacksonville, Florida. However, after
reviewing the workpapers of Revenue Agent Roberts, Appeals
Officer Whittle contacted Mr. Conner to advise him that a meeting
was unnecessary, as Appeals Officer Whittle was prepared to allow
the amounts of Schedule C deductions originally reported on
petitioners' Federal income tax returns for 1985, 1986, and 1987.
Mr. Conner indicated that he still preferred to meet on the
10In several instances, Office Auditor Barrow allowed
petitioners a deduction that was in excess of the amount claimed
on their return. See appendix.
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