- 5 - delivered safely to the Court through a diplomatic pouch. Petitioners delivered their Tax Court petition to the U.S. Embassy in Mexico City on August 17, 1994. On August 22, 1994, respondent assessed $181,637 in tax and $60,458.83 in interest for petitioners' 1990 tax year. On September 6, 1994, the petition in which petitioners disputed their 1990 income tax deficiency was filed in the Tax Court. On October 21, 1994, we granted respondent's motion to dismiss for lack of jurisdiction because petitioners' petition was not timely filed. D. Respondent's Reconsideration of Petitioners' Case On a date not stated in the record, Dietz asked respondent’s Los Angeles Appeals office to reconsider the assessment for 1990. The Appeals office agreed to do so. Catherine Keenan (Keenan), an Appeals officer for respondent in Los Angeles, obtained and reviewed the file for petitioners’ 1990 tax year sometime between October 21, 1994, and February 1, 1995. Keenan sent a letter to petitioners on December 30, 1994, inviting them to attend a conference. Petitioner met with Keenan on February 1, 1995, and gave her all the information he had. Keenan reviewed petitioners' case. She estimated the basis for the properties used in the section 1031 exchange. Keenan sent a written proposed settlement of the case to petitioners on March 2, 1995. On March 7, 1995, petitioners sent Keenan a facsimile message in which they acknowledged receipt of thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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