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sale may actually have been higher than the amount used in the
notice of deficiency.
If Ms. Samuels' recommended adjustment to the notice of
deficiency issued to the Alexanders for 1974 and 1975 had been
accepted, the total adjustments for 1975 would have been reduced
from $127,562 to $116,020, but the deficiency would not have been
eliminated.
Mr. McWade believed that Mr. Alexander was familiar with the
operation of Mr. Kersting's various programs. Before the trial
of the test cases, Mr. McWade arrived at a general understanding
with Mr. Alexander that the Alexanders' tax liabilities for the
taxable years 1974, 1975, 1976, and 1977 would be reduced in
exchange for Mr. Alexander's agreement to serve as an undeclared
consultant or assistant to Mr. McWade during the trial of the
test cases. Mr. McWade's understanding with Mr. Alexander is
reflected in decision documents that were executed by Mr. McWade
on April 6, 1989, and approved by Mr. Sims. In particular,
Mr. McWade executed a stipulated decision in docket No. 2758-80
conceding the deficiencies determined against the Alexanders for
the taxable years 1974 and 1975 and allowing the Alexanders
overpayments for the taxable years 1974 and 1975 in the amounts
of $2,133 and $811, respectively. In sum, Mr. McWade completely
eliminated all deficiencies determined against the Alexanders for
the taxable years 1974 and 1975 and relieved the Alexanders of
the concessions that they had made before the issuance of the
notice of deficiency for those years. The stipulation
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