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The parties stipulated the fact of this offer in compromise.
The record contains a copy of the offer in compromise dated
February 2, 1993, and the amended offer in compromise dated
December 3, 1993. Neither the stipulation nor copies of the
offers provide any detail as to the amounts or bases for
determination of liability for any of the tax years involved. We
note that the original offer was submitted February 2, 1993,
which is prior to the filing of the 1992 Federal income tax
return. The record is further unclear whether there was an
examination of the 1992 return and any additional tax determined
and/or assessed before the acceptance of the offer in compromise.
Thus, it is not clear whether, upon issuing Mr. Coyle a
notice of deficiency in connection with the case at hand,
respondent was reopening the offer in compromise with respect to
the 1992 tax year. See sec. 301.7122-1(c), Proced. & Admin.
Regs. Mr. Coyle has not alleged that the issuance of the notice
of deficiency in this case is an impermissible reopening of the
offer in compromise, and since the record does not provide
sufficient information in this regard, we decline to consider
this issue. Id.
Discussion
The primary issue in these cases is whether Regal omitted
gross receipts from the sale of wheels and axles and, if so,
whether Mr. Coyle omitted commission income received from Regal.
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