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scheduled date, and during his meeting with Appeals Officer
Whittle on June 29, 1994, Mr. Conner explained that petitioners
were claiming additional amounts of Schedule C deductions.
Appeals Officer Whittle originally believed that the period of
limitations was no longer open for 1985 and 1987.11
Nevertheless, despite finding that petitioners had a "weak case",
Appeals Officer Whittle ultimately agreed with Mr. Conner that
petitioners should be considered to have made an informal claim
for refund for which the period of limitations had not run and
that petitioners' claimed Schedule C deductions should be
allowed.
Petitioners then filed a claim with respondent to recover
the administrative costs incurred in connection with their case.
In a letter dated December 14, 1994, respondent denied
petitioners' claim for such costs. On January 26, 1995,
petitioners filed with the Court a petition for administrative
costs pursuant to section 7430(f)(2). The petition stated that
respondent had denied petitioners' claim for $9,311.12 of
administrative costs. The petition also stated that petitioners
were now claiming $13,586.12 of administrative costs.
11Since petitioners' 1986 year involved only a negligible
deficiency under the terms of the settlement agreement, the
parties did not discuss whether the period of limitations
remained open with respect to that year.
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