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$8,742 that was received on August 14, 1995. Petitioners did not
fully remit the tax shown on some of the returns at the time the
returns were filed.
On March 14, 1997, petitioners received from respondent a
so-called 30-day letter from the Commissioner's Examination
division proposing adjustments to petitioners' returns for the
years 1991 through 1994. Petitioners, by letter dated April 3,
1997, informed the Commissioner that they disagreed with the
proposed adjustments and requested an Appeals conference.
Petitioners and the Appeals officer handling their case reached a
settlement agreement with respect to the proposed adjustments to
their tax returns for 1991 through 1994. On November 6, 1998,
petitioners signed a Form 870, Waiver of Restrictions on
Assessment and Collection of Deficiency in Tax and Acceptance of
Overassessment, for tax years 1991 through 1994. They agreed to
an increase in tax of $4,899 for 1991, no increase for 1992, an
increase in tax of $5,800 and an addition to tax under section
6651(a) of $649 for 1993, and for 1994 an increase in tax of
$6,468 and an addition to tax under section 6651(a) of $1,379.
The Appeals officer explained to petitioners that by signing the
Form 870, they consented to the assessment and collection of the
deficiencies (including increases in tax and penalties) and
waived the right to petition the Tax Court to redetermine the
deficiencies. Petitioners were provided the opportunity to
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