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liabilities on their returns for the years in issue because he
thought they had not deducted enough for telecommunication
expenses (cell phones and pagers).
In 1997 and early 1998, petitioner told Annette Davis
(Davis), an employee of respondent,2 that he believed petitioners
had reported owing more tax than they owed. Davis recommended
that petitioners submit an offer in compromise.
D. Events From March 18, 1999,3 to October 8, 2001
1. March 18, 1999
Petitioner mailed a letter to Davis on March 18, 1999, in
which he referred to a conversation he had had with her. In that
conversation, petitioner had told Davis that he believed that
petitioners’ returns were incorrect because they did not include
deductions for telecommunication costs of about $5,000 per year.
On March 13, 2000, petitioner wrote to respondent and asked
respondent to consider petitioners’ situation as an economic
hardship case. In that letter, petitioner said that his accident
on December 13, 1996, had caused severe physical injuries to him
and substantial financial losses to his business.
2 Annette Davis’s position with respondent at that time is
not in the record. She later became a group manager.
3 Petitioners contend that interest on their underpayment
for 1991-95 that accrued from Mar. 18, 1999, to the present
should be abated.
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Last modified: May 25, 2011