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not all of the adjustments reflected in respondent’s above 30-day
letter. Upon respondent’s review of the additional records
provided, some adjustments set forth in the 30-day letter were
conceded by respondent, and on August 27, 1998, respondent issued
to petitioners a revised 30-day letter.
On July 16, 1999, after petitioners had provided to
respondent’s revenue agent yet additional records, respondent
issued to petitioners a second revised 30-day letter, reflecting
additional concessions by respondent.
Petitioners again protested to respondent’s Appeals Office
the adjustments set forth in respondent’s second revised 30-day
letter. Petitioners then provided to respondent’s Appeals Office
even more records relating to some of the remaining adjustments
that had previously not been provided. Upon review of these
records, respondent conceded or settled additional adjustments.
On December 7, 2000, respondent mailed to petitioners a
notice of deficiency for petitioners’ 1994 Federal income tax
liability that reflected the adjustments that had not been agreed
to, and on March 7, 2001, petitioners filed their petition
herein.
Shortly prior to the scheduled trial and as a result of
additional records provided by petitioners to respondent for the
first time, petitioners and respondent reached a basis for
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Last modified: May 25, 2011