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steadily, coordinating with IRS officials and counsel and with
representatives of the partnerships. He was instructed to begin
extending the settlement offer to individual partners in August
1995.
Petitioners--along with other partners of Green Leasing--
were sent a letter from the IRS dated November 30, 1995,
extending the final settlement offer. Petitioners accepted this
offer by letter dated January 24, 1996. The IRS then sent
petitioners an initial proposed closing agreement on August 2,
1996, incorporating the terms of the settlement offer. A revised
closing agreement--resulting from changes made because of
taxpayer inquiries--followed from the IRS on November 19, 1996.
This revised agreement was executed by petitioners on December 5,
1996, and for respondent on May 9, 1997. Thereafter, also in May
1997, the IRS in New York transmitted the executed closing
agreement to the Atlanta Service Center--the IRS service center
covering petitioners at that time--for determination of
petitioners’ tax liabilities resulting from the execution of the
agreement.
After the closing agreement was transmitted to Atlanta,
negotiations began between the IRS and petitioners. The IRS sent
petitioners initial calculations of their tax liabilities on or
around August 13, 1997. Thereafter, petitioners’ accountant sent
the IRS his own proposals, questions, and objections to the
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