Lawrence S. and Myrna Ahmaogak - Page 3

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               For convenience, only some of the details of the assessment            
          process for the underlying years are set forth in the body of               
          this opinion; additional details are contained in the Appendix.             
               By letter dated September 12, 1988, respondent notified                
          petitioners that their 1986 return was under examination.  That             
          return was selected for examination because of deductions claimed           
          for the donation of whale meat and whaling expenses.  The initial           
          interview with the petitioners took place on October 20, 1988.              
          On or around November 1, 1988, the examination was extended to              
          include petitioners’ 1987 return, on which similar deductions               
          were claimed.  An examination report proposing to disallow the              
          above-referenced deductions (presumably for both years) was                 
          mailed to petitioners on February 8, 1989.  Petitioners’ protest            
          was received on July 3, 1989, and an Appeals officer was assigned           
          2 weeks later.  On August 1, 1989, the Appeals officer scheduled            
          a conference with petitioners’ representative.  During Appeals              
          consideration, much correspondence was exchanged, and several               
          conferences took place.  On June 14, 1991, respondent’s Appeals             
          Office issued a notice of deficiency to petitioners in which                
          deficiencies in their 1986 and 1987 income taxes were determined.           
          Petitioners timely petitioned this Court in response to that                
          notice on September 16, 1991 (docket No. 20784-91).  That                   
          docketed case was set for trial but was continued several times.            
          Ultimately, a stipulated decision was entered on February 29,               

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