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indicated that he wanted to litigate all the issues related to
First Energy and that he was willing to be bound by a test case.
The following year, in a letter dated January 12, 1989,
petitioner's counsel wrote to respondent's counsel expressing a
desire to "proceed with the government's settlement offer" and
requesting a computation showing the settlement deficiencies. In
a letter dated June 27, 1989, respondent sent to petitioner's
counsel copies of a proposed decision, stipulation, and closing
agreement together with a computation of tax. In this proposed
settlement, petitioner would agree to a deficiency in tax for
1980 of $6,330. He would also agree to a deficiency in tax for
1983 of $4,613, net tax payments of $5,717, and an overpayment of
$1,104. The parties would also make certain concessions as to
additions to tax and additional amounts to be paid under section
6621(c).
Respondent's counsel wrote to petitioner's counsel in a
letter dated October 17, 1989, to inform him that petitioner had
contacted respondent's counsel and alleged that he had not
received the $6,330 refund for 1980 that he had applied for on
Form 1045. In the letter, respondent's counsel also informed
petitioner's counsel that a pretrial conference in unsettled
First Energy cases was being scheduled requiring the receipt of
any agreed decision before November 3, 1989. There was no
acceptance of the offer.
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