2
At the time their petition was filed, petitioners resided in
Houston, Texas. References to petitioner are to Girish Patel.
The Internal Revenue Service, Austin, Texas, Service Center
(IRS) mailed a letter (30-day letter) to petitioners on September
25, 1996, proposing changes in their 1994 income tax return. On
the schedule attached to the 30-day letter, respondent increased
taxable income by $7,161, resulting in an increase of $1,072 in
petitioners’ 1994 tax liability. The adjustments were (1) $7,146
of additional interest income from two accounts at NationsBank of
Texas, and (2) $15 of additional wage income. Respondent’s
adjustments were based upon a comparing of the amounts reported
on petitioners’ Federal income tax return for wages and interest
with Forms W-2 and Forms 1099 received from the payors. The 30-
day letter stated:
If you don’t agree with the proposed changes on page 2:
- Check box B on the last page of this notice,
- Enclose a signed statement explaining why you
disagree,
- Include any supporting documents you wish us to
consider, and
- Use the envelope enclosed to return the last page of
this notice with your statement and documents. Please
include a telephone number, including an area code, and the
best time to call you.
The letter stated that if the IRS did not receive a response
within the 30-day period, a notice of deficiency would be issued.
Petitioners would be able to contest the notice of deficiency in
Court. Petitioners did not respond to the 30-day letter, nor did
they request an Appeals Office conference.
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