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resolved is whether such decision by respondent constitutes an
abuse of discretion.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulation of facts and the exhibits submitted therewith are
incorporated herein by this reference.
At the time the petition was filed in this case, petitioners
resided in Atlanta, Georgia.
By letter dated March 4, 1994, the Internal Revenue Service
(IRS) notified petitioners that their 1990 and 1991 joint Federal
income tax returns had been selected for examination. On November
7, 1994, the IRS sent petitioners a copy of the examination report,
which contained adjustments increasing petitioners’ tax obligation
for 1990 and 1991. By letter dated November 22, 1994, the IRS
informed petitioners that they had 15 days to request that their
case be transferred to an IRS Appeals Officer. By letter dated
December 2, 1994, instead of requesting that their case be so
transferred, petitioners requested a meeting with an examiner and
stated that they did not agree with the examination report. On
January 9, 1995, petitioners executed Form 872, Consent to Extend
the Time to Assess Tax, extending the period for assessing taxes
for both 1990 and 1991 to April 15, 1996.
On April 12, 1995, respondent, by certified mail, sent a
statutory notice of deficiency to petitioners at their last known
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