Curtis and Mary Ettesvold - Page 8

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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                   
                 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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