Haas & Associates Accountancy Corporation - Page 6




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               I received your revenue agent’s report and cover letter                
               dated October 21, 1997.  As we discussed, I do not                     
               agree with your audit report and its findings.  I                      
               believe the tax returns in question were filed                         
               accurately.  As per your letter, you may then close the                
               case as unagreed and I will appeal the findings in                     
               court.                                                                 

               On March 18, 1998, respondent mailed to Haas and his wife              
          and to Haas & Associates 30-day letters that reflected the same             
          adjustments that were reflected in the above revenue agent’s                
          reports.  Respondent’s 30-day letters explained the protest                 
          rights available to Haas and his wife and to Haas & Associates to           
          administratively appeal the proposed adjustments.1                          
               Haas and his wife and Haas & Associates did not file a                 
          protest or request a conference with respondent’s Appeals Office            
          with regard to the above proposed adjustments in their Federal              
          income tax liabilities.                                                     
               On June 10, 1998, respondent closed his audit regarding Haas           
          and his wife for 1993 and regarding Haas & Associates for 1994              
          and 1995.                                                                   




          1    Although respondent at trial could not locate a copy of the            
          30-day letter mailed to Haas and his wife, and although                     
          petitioners did not produce a copy thereof, the limited evidence            
          in the record on this point indicates that on Mar. 18, 1998,                
          respondent mailed a 30-day letter to Haas and his wife that                 
          reflected the same adjustments that were reflected in the revenue           
          agent’s report that had been mailed to Haas and his wife on                 
          Oct. 21, 1997.                                                              





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