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petitioners’ motion on the basis of the limitation imposed
by section 7430(b)(1). We need not, and do not, reach the
other issues raised by respondent.
Respondent’s response to petitioners’ motion points out
that a 30-day letter was issued to petitioners. See sec.
601.105(d), Statement of Procedural Rules. A copy of that
30-day letter is attached as an exhibit to respondent’s
response. The letter pointed out that if petitioners did
not agree with the proposed changes in their 1994 and 1995
returns, then they could obtain a conference with the
Regional Office of Appeals. The 30-day letter also
explained the steps necessary to obtain such an Appeals
conference.
Respondent’s brief further represents that after
issuing the 30-day letter, respondent’s agent contacted
petitioners’ representative. According to respondent’s
response, petitioners’ representative advised the agent that
petitioners did not agree to the adjustment, but they would
not file a protest. Petitioners’ representative recommended
that the agent issue a notice of deficiency.
The 30-day letter issued to petitioners proposes
increasing their net earnings from self-employment for 1994
and 1995 by the amount of the real estate rental payments
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