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interest. We hold he did not. Unless otherwise indicated,
section references are to the applicable versions of the Internal
Revenue Code. Rule references are to the Tax Court Rules of
Practice and Procedure.
FINDINGS OF FACT
Some facts were stipulated. We incorporate herein by this
reference the parties’ stipulation of facts and the exhibits
submitted therewith. We find the stipulated facts accordingly.
Petitioners are husband and wife. They resided in Hastings,
Michigan, when their petition was filed with the Court.
Petitioners filed timely 1990 and 1991 joint Federal income
tax returns and paid the reported taxes. Respondent audited
those returns in 1993 and disallowed certain claimed business
expenses. Respondent’s disallowance of these expenses increased
petitioners’ tax liability for 1990 and 1991. Respondent also
determined during the audit that petitioners were liable for 1990
and 1991 accuracy-related penalties under section 6662(a).
On September 17, 1993, petitioners agreed to the assessment
of the amount of taxes and penalties determined by respondent.
Subsequently, on several occasions, petitioners offered to
respondent a compromise of the amount of those assessed amounts.
Respondent rejected each of these offers.
On December 28, 2000, petitioners filed with respondent
Forms 843, Claim for Refund and Request for Abatement, for 1990
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