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On September 20, 1991, respondent issued a letter to
petitioner stating that an examination of his returns for the
1981 and 1982 years showed no change was necessary in the
reported tax (no-change letter).
Shortly thereafter, an agent of respondent began the process
of reopening the examination of petitioner's 1981 and 1982 tax
years. It was explained in the agent's request for approval of
the reopening, dated December 12, 1991, that, upon notification
by the U.S. Attorney's office that petitioner had requested the
District Court to vacate his conviction based on the no-change
letter, the chief, examination division, who had not been a party
to the original decision, had reviewed the circumstances and
information relating to the decision to issue the no-change
letter. As a result, it was determined that, based upon the tax
evasion conviction and various unresolved questions, failure to
reopen would result in serious criticism of the Service's
administration of the tax laws, and establish a precedent that
would seriously hamper future actions.
Subsequently, on December 13, 1991, respondent issued a
letter to petitioner signed by the chief, examination division,
requesting that petitioner make available his books and records
for a reexamination (reopening letter). On June 2, 1994, the
notice of deficiency herein was issued.
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