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payment addition for 1995 and 1996. On October 11, 2001, Leiba
wrote Estoll to accept respondent’s settlement offer. On October
29, 2001, respondent’s Appeals Office confirmed that respondent
had agreed to abate the late payment addition for 1993.
On December 10, 2001, Leiba wrote to Charles Checchi
(Checchi), respondent’s area director in San Francisco, to ask
him to approve petitioners’ claim for refund of the late payment
addition for 1995 and 1996.
C. Administrative Costs Claim
On January 22, 2002, Leiba wrote to Checchi to request
payment of petitioners’ administrative costs. On March 28, 2002,
Checchi wrote Leiba to inform him that he had spoken to Estoll
about the case and decided not to reconsider the settlement for
1995 and 1996.
On April 23, 2002, Checchi wrote to inform Leiba that he was
reassigning petitioners’ claim for administrative costs to an
Appeals Office separate from the one that had considered
petitioners’ previous claims.
On February 10, 2003, Darwyn Pearl (Pearl), Appeals Team
Manager in Seattle, Washington, wrote to petitioners. Pearl
stated that petitioners’ claim for administrative costs under
section 7430 was disallowed because (1) petitioners had not
substantially prevailed on the amount in controversy or on the
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