Jean Mathia and Estate of Doyle V. Mathia, Deceased, Jean Mathia, Personal Representative - Page 4

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               On August 5, 2005, respondent issued to petitioners a notice           
          of determination with respect to the Notice of Intent to Levy and           
          a second notice of determination with respect to the Notice of              
          Federal Tax Lien Filing.  On August 18, 2005, respondent issued a           
          notice of final determination denying petitioner’s interest                 
          abatement claims.  Petitioners timely filed a petition contesting           
          each of respondent’s determinations.  Petitioners contend that              
          the period of limitations on assessment had expired before                  
          respondent had assessed petitioners’ 1982-84 tax liabilities.               
          Petitioners further contend that respondent improperly denied               
          their interest abatement claims.                                            
               This case was scheduled for trial during the trial session             
          of the Court beginning March 6, 2006, at Oklahoma City, Oklahoma.           
          On March 6, 2006, the parties filed a Stipulation of Facts                  
          (Stipulation) and a Joint Motion for Leave to Submit Case Under             
          Rule 122, which motion we granted that same day.  The                       
          Stipulation, which was signed by both parties, contains 21 pages            
          and states that “the parties agree to this Stipulation of Facts”            
          and “All stipulated facts shall be conclusive.”  We established a           
          posttrial briefing schedule that required the parties to submit             
          their opening briefs on or before May 5, 2006.                              
               On April 27, 2006, approximately 1 week before opening                 
          briefs were due, we had a conference call with the parties at the           
          request of respondent’s counsel.  During that conference call,              






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