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examine the form, and in fact they took the opportunity to review
it before they signed it.
On December 3, 1998, petitioners signed a Form 3363,
Acceptance of Proposed Disallowance of Claim for Refund or
Credit. The form disallowed their claim for refund or credit in
the amount of $8,742 on the Form 1040X submitted on August 14,
1995, for the 1991 tax year. The form states that the Internal
Revenue Service (IRS) will not consider the subject claim but
that the taxpayer retains the right to sue the IRS on the
disallowance. Also on December 3, 1998, petitioners signed Form
2297, Waiver of Statutory Notification of Claim Disallowance.
The waiver informs the signatories that it begins the 2-year
period for filing suit for refund of the disallowed claim.
On April 12, 1999, the IRS sent to petitioners a letter for
each of the years 1991, 1993, and 1994, advising them of an
"increase in tax because of examination action". The letters
demanded payment for taxes, penalties, and interest related to
the agreed deficiencies listed on the Form 870 that petitioners
signed on November 6, 1998.
On June 2, 2000, the IRS sent to petitioners a Final Notice,
Notice of Intent to Levy and Notice of Your Right to a Hearing
for unpaid amount of tax of $9,767.04 for 1997 and "additional
penalty and interest" of $548.41 for 1993 and $2,684.78 for 1997.
Petitioners asked for and received a hearing under section 6330.
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