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officer. The January 24, 1994, meeting was held, and the parties
discussed petitioners' case. The Appeals officer described to
petitioners the nature of respondent’s determinations.
Petitioners explained their position in the matter and produced a
small amount of evidence to support their arguments. The Appeals
officer was not satisfied that petitioners had proven any error
in respondent’s determinations but indicated that he would review
the matter and send petitioners a list of evidence they needed to
produce to overcome respondent’s determinations.
Nothing else transpired until July 5, 1994, when another
Appeals officer advised petitioners by letter that the case had
been reassigned to him because of workload considerations,
suggested a meeting at the Appeals Office at Ft. Lauderdale
possibly to settle the case, and provided his assessment of
petitioners' case. Petitioners responded that they could not
meet on the suggested date and proposed a meeting at Ft. Myers,
Florida, in September 1994. The Appeals officer responded that
he was not going to Ft. Myers until late October and suggested
petitioners come to his Ft. Lauderdale office in late September
or October 1994 to attempt settlement.
In the meantime, on August 5, 1994, the IRS office of
District Counsel advised petitioners by letter that their case
was calendared for trial at this Court’s trial session at Miami,
Florida, commencing December 5, 1994, and it was necessary that
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