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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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Last modified: May 25, 2011