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There were located on the original and copy of the Forms
5701 that respondent’s representatives provided to Exxon’s
representatives a set of boxes, and Exxon’s representatives were
requested to check one of the boxes to indicate whether they
agreed, agreed in part, or disagreed with the proposed
adjustments and to return to respondent's representatives the
copies of the Form 5701. Exxon's representatives, however,
following a policy decision that had been made, did not indicate
in the boxes or otherwise on the Forms 5701 whether or not Exxon
agreed, agreed in part, or disagreed with respondent's proposed
adjustments.
Over the years, Exxon’s representatives used different
methods to communicate in writing to respondent’s representatives
Exxon’s agreement to specific adjustments. As indicated, the
Forms 5701 were not used by Exxon’s representatives to
communicate to respondent's representatives Exxon’s agreement to
specific adjustments. Exxon’s representatives did communicate in
writing to respondent’s representatives Exxon’s agreement to
certain adjustments that respondent had raised for the years in
issue by entering into written Form 870 agreements (Waiver of
Restrictions on Assessment and Collection of Deficiency in Tax
and Acceptance of Overassessment) and Form 870-AD agreements
(Offer to Waive Restrictions on Assessment and Collection of Tax
Deficiency and to Accept Overassessment) and by making
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Last modified: May 25, 2011