- 9 - did not pay any Federal income tax at the time they filed the 1995 joint return. By February 3, 1997, petitioner and Mr. Mellen paid in full the Federal income tax due shown in that return, a penalty, and interest thereon. Sometime during 1997, an agent of respondent (examining agent) commenced an examination of the 1995 joint return (respon- dent’s examination). Sometime after that examination commenced but before September 8, 1998, the examining agent proposed nine adjustments (proposed adjustments) to the 1995 joint return, which included the proposed disallowance of the claimed casualty loss deduction of $30,930. As grounds for that proposed disal- lowance, the examining agent concluded that if the alleged casualty occurred at all, it occurred during 1994. Sometime after the examining agent proposed those adjustments but before September 8, 1998, petitioner and Mr. Mellen disagreed with the proposed adjustments and requested and had a conference with the Internal Revenue Service (IRS) Appeals Office. During that conference, the IRS Appeals Office sustained only one of the adjustments proposed by the examining agent, namely, the proposed disallowance of the claimed casualty loss deduction. On September 8, 1998, petitioner and Mr. Mellen signed Form 870, Waiver of Restrictions on Assessment and Collection of Deficiency in Tax and Acceptance of Overassessment, in which they agreed to the disallowance of the claimed casualty loss deductionPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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