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project settlement offer was extended to them, but they do not
claim to have accepted the offer timely, so they effectively
rejected it.11
In December 1988, the Miller cases were disposed of by
settlement agreement between the taxpayers and respondent.12
This Court entered decisions based upon those settlements on
December 22, 1988. The settlement provided that the taxpayers in
the Miller cases were liable for the addition to tax under
section 6659 for valuation overstatement, but not for the
additions to tax under the provisions of section 6661 and section
6653(a). The increased interest under section 6621(c), premised
solely upon Miller's interest in the recyclers for the taxable
years at issue, was not applicable because Miller made payments
prior to December 31, 1984, so no interest accrued after that
10(...continued)
respondent attached a copy of a settlement offer that was
extended to petitioners and other taxpayers who at the time were
represented by counsel other than their present counsel. The
terms of the offer were as stated above, except that no mention
was made with respect to the execution of a closing agreement
(Form 906) stating the settlement and resolving the entire matter
for all years.
11 In their motion for decision, petitioners state:
"Respondent formulated a standard settlement position which was
extended to all taxpayers having docketed or non-docketed cases
in the plastics recycling group, including Petitioner." (Emphasis
added.)
12 Although it is not otherwise a part of the record in this
case, respondent attached copies of the Miller closing agreement
and disclosure waiver to her objection to petitioners' motion for
leave, and petitioners do not dispute the accuracy of the
document.
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