-10-
of the hearing, the Court directed the parties to file legal
briefs.
FINDINGS OF FACT
The parties have stipulated some facts, which we incorporate
herein by this reference.
After the petitions were filed in these cases, petitioners,
directly and indirectly through Mr. Kauffman, attempted to work
with respondent’s revenue agent toward settlement. After four
continuances of these cases, Ms. Miller sent Mr. Kauffman a
letter dated April 10, 2003, enclosing a revenue agent’s report
and corresponding computations, along with a settlement proposal
for both cases. Ms. Miller’s letter stated that trial was
scheduled for May 19, 2003, that petitioners had repeatedly
delayed this matter, and that it was her belief that the Court
would allow no further delays. The letter stated that, in
preparing the report upon which the settlement offers were based,
the revenue agent had considered and, for the most part, accepted
the latest information provided by petitioners. With respect to
the Gazis’ case, the letter stated that for settlement purposes
only, respondent would agree to substitute negligence penalties
for the civil fraud penalty, and that the settlement offer would
result in a reduction of about $500,000 in taxes and of about
$300,000 in penalties. With respect to the All Community Walk In
Clinic case, the letter stated that “because the petitioners have
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