Ted and Tammy Estes - Page 6

                                        - 6 -                                         
                                        1992        1993      1994                    
                    Deficiencies        $18,647   $2,164    -0-                       
                    Penalties           3,729     -0-       -0-                       
                    Additions to tax    -0-       -0-     -0-                         
                    Total               22,376    2,164     -0-                       
          Petitioners rejected this settlement offer.                                 
               Counsel for both parties, along with respondent’s Appeals              
          officer, met on March 23, 1999.  Counsel again met on April 2,              
          1999, this time with petitioner present.  Respondent and                    
          petitioners dispute whether and to what extent new evidence was             
          given in these later stages of negotiation to substantiate the              
          amounts claimed as cost of goods sold.  The parties also dispute            
          whether petitioners’ personal conversations with respondent’s               
          counsel yielded information previously not available to                     
          respondent.  After this meeting, however, respondent made the               
          decision to concede the case in whole to petitioners.                       
               A stipulated decision was entered on May 11, 1999.  The                
          decision document stated that petitioners were not liable for any           
          deficiencies, penalties, or additions to tax.1  The Statement of            
          Income Tax Changes–-prepared by respondent and filed with the               

          1  The Statement of Income Tax Changes lists an                             
          overassessment for taxable year 1992 in the amount of $1,376.               
          The decision document, however, states that there were no                   
          overpayments in the years at issue.                                         

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