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aggressively asserting their rights in dealings with respondent.
See Butti v. Commissioner, supra.
Petitioners have litigated in this Court previously. In
Maxfield v. Commissioner, T.C. Summary Opinion 2006-27,
petitioners challenged respondent’s deficiency determinations for
the taxable years 2000 and 2001. This supports petitioners’
contention that they always reply to respondent’s notices and
letters.
Petitioners also have a long history of dealing with
respondent. According to petitioners, respondent has examined at
least nine of their tax returns. The parties acknowledge that
the examination of petitioners’ 1999 return was particularly
contentious. For example, petitioners sent letters to the
Commissioner of Internal Revenue and the National Taxpayer
Advocate complaining about the examination. One letter states in
part: “On 14 February 2002 * * * [an Internal Revenue Service
agent] came out to my home and conducted an audit of my 1999 tax
return. I produced all my 1999 tax records and for 9 and ½ hours
we went through the audit. I enjoyed it, it was fun.” While the
sarcasm in the letter is evident, we have no doubt that
petitioner derives a sense of satisfaction from challenging
respondent.
Petitioners ultimately asked respondent to close the
examination and issue a notice of deficiency. After respondent
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