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Mazon requested transcripts from the Fresno Service Center in
order to reconcile and verify amounts shown on petitioners' tax
returns with amounts reflected in respondent's computer system.
On July 19, 1990, Agent Mazon's manager, Ms. Malilay,
requested that work on the case be suspended pending resolution
of a related audit of NERC. On September 19, 1990, Agent Mazon
wrote a report and attached Forms 886-A, Explanation of Items.
On October 3, 1990, Agent Mazon mailed out the 30-day letter to
petitioners and mailed a copy to Mr. Berg. The 30-day letter
proposed adjusting unreported income for all 3 years at issue.
The 30-day letter also proposed the assertion of the fraud
penalty and, in the alternative, the negligence penalty. By
cover letter dated October 26, 1990, petitioners filed a protest.
The protest letter was received on November 7, 1990.
On December 4, 1990, the case file was transferred to
respondent's San Diego Appeals Office. On February 13, 1991,
respondent mailed a letter to Mr. Berg notifying him that the
case was assigned to the San Diego Appeals Office. On April 29,
1991, Appeals Officer Carol Holt wrote Mr. Berg informing him
that the case had been assigned to her. On September 6, 1991,
petitioners executed a Form 870, settling the case. In the Form
870, Waiver of Restrictions on Assessment and Collection of
Deficiency in Tax and Acceptance of Overassessment, petitioners
agreed to the additional income amounts that Agent Mazon
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