Stephen J. Roling and Peggy A. Roling - Page 6




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          1999, petitioners' EA sent to Appeals a copy of a handwritten               
          note as evidence of a loan of $10,000 from petitioner's father to           
          them in July of 1994.                                                       
               On June 22, 1999, Appeals issued the notice of deficiency in           
          this case containing the $15,672 adjustment denying the timber              
          contract downpayment deduction, the unreported income adjustment            
          of $5,061, and the adjustment determining an accuracy-related               
          penalty under section 6662.                                                 
          Post-Appeals                                                                
               The petition was filed with the Court on September 20, 1999,           
          and by notice dated March 29, 2000, was set for trial at the                
          Court's Des Moines trial session beginning on June 19, 2000.                
               Petitioners retained counsel to represent them in this                 
          matter.  Counsel for the parties discussed the timber cutting               
          contracts and the unreported income issues for a period of weeks.           
          Counsel for the parties agreed that inventorying was not                    
          appropriate treatment for petitioners' timber payments.  During             
          their discussions, counsel for petitioners provided respondent's            
          counsel with documentation showing that with respect to two of              
          the five contracts, trees were cut and sold in 1994.  Since the             
          income for the sale of the trees was reported in the same year as           
          the deduction of the downpayment, the adjustment for the two                
          contracts totaling $8,950 was conceded by respondent's counsel.             
          As part of the overall settlement, petitioners agreed that the              






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