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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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