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filed their petition with this Court on August 8, 1997. At the
time their petition was filed, petitioners resided in New
Orleans, Louisiana.
Respondent filed an answer on September 11, 1997. Shortly
thereafter, the case file was forwarded to respondent's Appeals
Office in New Orleans, Louisiana, where the case was assigned to
Appeals Officer Gregory M. Berry (Mr. Berry). The administrative
file received by Mr. Berry bore no indication that petitioners
had provided respondent with any information or response to the
30-day letter.
On September 15, 1997, Mr. Neilson wrote to Mary Beth
Calkins at respondent's District Counsel office in New Orleans.
Mr. Neilson asserted that the disputed amount of $156,931 was a
"direct rollover" by petitioners from American Express to an IRA
with Southwest Securities, Inc. (Southwest). Attached to the
letter were copies of documents purporting to support
petitioners' position, including an application by Mr. Uddo for
an IRA with Southwest, a letter requesting a transfer of Mr.
Uddo's accounts with IDS (American Express), and "portfolio
summary" statements from Southwest.
In a letter dated September 18, 1997, Mr. Berry wrote to
acknowledge respondent's receipt of Mr. Neilson's September 15,
1997, letter and the supporting documentation. Mr. Berry stated
that from his review of the supporting documentation he was
unable to tie the information to the disputed amount and
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