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petitioner5 deducted on her 1985 and 1986 Federal income tax
returns, respectively.
On July 16, 1999, respondent issued a notice of deficiency
to petitioners for 1982 and 1983 in which he determined that
petitioners are liable for additions to tax for negligence
pursuant to section 6653(a)(1) and (2) for 1982 and 1983 in
connection with our decision entered against Jojoba.
On July 2, 1999, respondent issued a notice of deficiency to
petitioner for 1985 and 1986 in which he determined that
petitioner is liable for additions to tax for negligence pursuant
to section 6653(a)(1) and (2) for 1985 and pursuant to section
6653(a)(1)(A) and (B) for 1986 in connection with our decision
entered against Jojoba.
Discussion
I. Consistent Settlement Offer
The first issue we must decide is whether respondent is
required to enter into a consistent settlement agreement with
petitioners under section 6224. We address this issue assuming,
but not deciding, that the issue is properly before the Court.
Petitioners contend that respondent is obligated to offer them
terms of settlement consistent with settlement agreements entered
5Mr. Myers died in 1984. In late 1984, petitioner attended
a class in Federal income tax at Hawaii Pacific College. In 1988
and 1989, petitioner completed classes in basic and intermediate
income tax preparation at H&R Block.
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