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On December 29, 1997, respondent issued a notice of
deficiency to petitioner determining fraud penalties under
section 6663 for 1992 and 1993. Petitioner filed a timely
petition in this Court, seeking a redetermination of the fraud
penalties for 1992 and 1993.
On July 6, 1998, petitioner’s conviction was affirmed by the
Court of Appeals for the Sixth Circuit.
On or about August 3, 1998, petitioner received a letter
from respondent stating in part: “Thank you for your inquiry of
June 05, 1998. We have resolved your problem with your 1989 tax
return. Please disregard the prior request.”
By memorandum dated March 3, 1999, District Counsel of
respondent advised respondent’s Examination Division that the
criminal proceedings against petitioner were concluded.
In connection with the proceedings in this Court concerning
a redetermination of the 1992 and 1993 fraud penalties,
petitioner and respondent became involved in a dispute over
discovery and a continuance of the trial. On July 16, 1999,
petitioner requested a continuance, which was granted on July 20,
1999. On July 19, 1999, the revenue agent who conducted the
examination of petitioner’s 1992 and 1993 taxable years met with
respondent’s counsel at the U.S. attorney’s office to review the
record in petitioner’s criminal case. At that time, upon a
review of the criminal case record and the administrative file,
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