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explaining the error and advising them they owed an additional
$1,387.25, including interest of $35.08.
On May 29, 1991, respondent first notified petitioners that
their 1989 return had been selected for examination. At the
time, petitioners resided in Barrow, Alaska, and the revenue
agent assigned to the examination was located in Fairbanks,
Alaska. We cannot determine whether petitioners or anyone acting
on their behalf met with the revenue agent during the
examination. Because of the distance between petitioners’
residence and the revenue agent’s post of duty, there might have
been some logistical complications in scheduling meetings, and
there appear to have been some delays in the receipt of
correspondence mailed between petitioners and the revenue agent.
The revenue agent’s report was mailed to petitioners on
December 16, 1991.4 Having received no protest to the revenue
agent’s report by March 18, 1992, respondent began the process of
preparing a notice of deficiency that was mailed to petitioners
on March 23, 1992. In that notice of deficiency respondent
determined a deficiency of $7,475 in petitioners’ 1989 Federal
4 This date is erroneously listed as “December 16, 1992” in
the chronology of events prepared by the Appeals officer.
Although an obvious error, petitioners make repeated references
to the event as though it actually occurred in 1992.
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