Tam N. Huynh - Page 4




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          that petitioner wished respondent to consider should be received            
          within 15 days of the date of the May 11th letter.                          
               By a notice of deficiency dated May 28, 1999, respondent               
          determined a deficiency of $4,196 in petitioner’s 1998 Federal              
          income tax.  Petitioner hired counsel to represent him in June              
          1999.  The petition was filed August 9, 1999.  Respondent’s                 
          answer was filed October 12, 1999.                                          
               On November 3, 1999, respondent assigned the case to an                
          Appeals officer.  On November 18, 1999, the Appeals officer spoke           
          with petitioner’s counsel about settling the dispute.  The                  
          following day, the Appeals officer mailed a letter to                       
          petitioner’s counsel proposing that respondent would concede the            
          earned income credit issue if petitioner conceded the dependency            
          deductions and head of household filing status issues.                      
               On January 11, 2000, the Appeals officer received a letter             
          from petitioner’s counsel suggesting that she agree to concede              
          all three issues.  Attached to the letter were documents                    
          concerning petitioner’s public assistance, dependency deductions,           
          and filing status.  After reviewing the letter and documents, the           
          Appeals officer did not alter her settlement position.                      
               In February 2000, the Appeals officer forwarded the case to            
          respondent’s District Counsel office for trial preparation.                 
          After reviewing the case, the District Counsel office offered to            
          settle the dispute with petitioner on the same terms that had               






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