3
did not know when his job in Athens would end and requested that
the examination be moved to the IRS office nearest to Knoxville,
Tennessee.
On June 3, 1991, the Chattanooga, Tennessee, IRS District
Office mailed a letter to petitioners at 2108 Congress Parkway
#208, Athens, Tennessee, informing them again that their 1988 and
1989 returns were selected for examination and asking that they
schedule a meeting. Petitioner notified the Chattanooga office
on June 27 that its letter of June 3 had been forwarded by his
former landlord in Tennessee to his sister in Fort Worth, whose
son then called petitioner in California. Petitioner scheduled a
meeting with the IRS for September 3 and 4, 1991, in California.
In a letter to the IRS dated August 28, 1991, petitioner
explained that he was laid off from his job in California in
July, causing him to move to Waltham, Massachusetts, and asked
that the examination scheduled for September 3 and 4 be
rescheduled and moved to the IRS office nearest to Waltham.
In a letter dated February 11, 1992, the IRS office in
Boston, Massachusetts, informed petitioners that the examination
of their 1988 and 1989 returns had been rescheduled for February
27, 1992, at the Boston office. On February 21, 1992, petitioner
sent a letter to the IRS Boston office informing them that he
would be unable to attend the February 27 appointment because he
was laid off from his position in Massachusetts. At this time,
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