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employment or income tax was withheld from Mr. Anderson’s fishing
income, and petitioners did not report or pay any self-employment
tax for the years in issue. On their 1996 and 1997 tax returns,
petitioners reported income tax liabilities in the amounts of
$4,924 and $3,491, respectively. Respondent assessed the
reported income tax liabilities for petitioners’ 1996 and 1997
years on May 26, 1997, and June 8, 1998, respectively.
In a January 30, 1997, statutory notice of deficiency
respondent determined that petitioners were liable for 1995 self-
employment tax. Respondent also determined that petitioners were
entitled to a corresponding deduction for one-half of the self-
employment tax liability. Petitioners requested that the January
30, 1997, notice of deficiency be rescinded so they could attempt
to resolve the matter at the Internal Revenue Service (IRS),
Office of Appeals (Appeals). The January 30, 1997, notice of
deficiency was rescinded, but petitioners did not have an Appeals
conference. On May 6, 1997, respondent issued a second notice of
deficiency determining a 1995 self-employment tax deficiency.
Petitioners also requested Appeals to send their 1995 self-
employment tax issue to the national office of the IRS for
technical advice, but their request was denied. In a May 27,
1997, letter, responding to the refusal to submit the matter for
technical advice, petitioners acknowledged receipt of the May 6,
1997, notice of deficiency for 1995. In a subsequent letter,
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