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over the tax years at issue. Instead, according to respondent,
petitioner attempted to allocate only the additional $12,000
(which we discuss in greater detail below). The $42,873.24 was
paid by petitioner in restitution as part of the resolution of
the criminal tax charges for which he was convicted. In the pre-
sentence investigation report prepared by the U.S. Department of
Probation, upon which petitioner was ordered to pay restitution
to the Internal Revenue Service (IRS), petitioner’s additional
income and resulting Federal income tax liabilities for each of
the 1990, 1991, 1992, and 1993 tax years were detailed with
specificity.4 That petitioner did not reproduce the pre-sentence
report as part of his offer letter does not make the offer any
less clear. We find petitioner’s offer to be clear as to the
amount offered as petitioner’s liability--$54,873.24.
Respondent next argues that petitioner’s offer was not valid
because it was not with respect to all of the adjustments at
issue and only those adjustments as required by section 301.7430-
7(c)(3), Proced. & Admin. Regs. Respondent argues because the
$42,873.24 was paid in restitution more than 6 years ago pursuant
to a criminal judgment entered against petitioner, it was not an
adjustment at issue in this case. As discussed above, the
4The pre-sentence report was specific enough to include
additional income such as petitioner’s receipt of a stereo in
lieu of payment from a client which he then gave to his
girlfriend discussed in Jondahl v. Commissioner, T.C. Memo. 2005-
55 (slip op. at 40).
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