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not entitled to treat the sale of the building in Los Angeles and
purchase of the houses in Phoenix as a like-kind exchange because
petitioners had not substantiated their basis in the properties.
On June 1, 1993, Morrow sent her report to petitioners and
Feldman. On June 9, 1993, Morrow invited petitioners to a
meeting on June 15, 1993. Neither petitioners nor Feldman
attended that meeting. Morrow then closed the case.
C. Filing and Dismissal of Petitioners' Tax Court Petition
Petitioners moved to Mexico City on July 1, 1993. On
October 8, 1993, Feldman sent a facsimile message to petitioners
saying that he had not received any correspondence from
respondent since June 1, 1993.
On November 16, 1993, respondent’s examination division
asked district counsel to review a proposed notice of deficiency
for petitioners' 1990 year. Respondent sent the notice of
deficiency to petitioners in Mexico on March 24, 1994.2
On February 21, 1994, respondent sent petitioners a $5,385
refund because petitioners had overpaid tax for 1990, 1991, and
1992.
In April or May 1994, petitioner contacted Daniel Dietz
(Dietz), respondent's representative at the U.S. Embassy in
Mexico City. Dietz suggested that petitioners bring their Tax
Court petition for the 1990 year to him so that it could be
2 Petitioners' petition must have been filed, or mailed to
this Court, by Aug. 22, 1994, to be timely. See sec. 6213(a).
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