- 6 - 1984, 1985, and 1986, and that respondent should stop collection from petitioner. On April 1, 1991, respondent responded to petitioner's letter that respondent received on January 7, 1991. Respondent stated that petitioner owed $317.16 for 1984, $13,256.89 for 1985, and $477.94 for 1986 (including penalties and interest to April 21, 1991). Respondent said that petitioner must pay the tax due and claim a refund if he did not agree with the adjustment. On April 17, 1991, Kelly wrote to respondent's problems resolution officer in Seattle, Washington, to explain why he believed respondent's position was incorrect. On April 23, 1991, respondent assigned petitioner's case to a problems resolution office. On May 7, 1991, respondent's quality assurance staff wrote a memo to respondent's problems resolution office. In it, the quality assurance staff concluded that the assessments were invalid because respondent assessed more than the amounts shown on the returns. Also, on May 7, 1991, respondent's problems resolution office wrote to Kelly and said the assessments were valid for 1986, but invalid for 1984 and 1985 because respondent did not issue a notice of deficiency for those years. On June 24, 1991, respondent abated petitioner's over- assessment, additions to tax, and accrued interest for 1984, but did not abate the assessment of tax for amounts shown onPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011