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petitioner was living at the Fort Worth address and asked that
the examination be moved to the IRS office in Fort Worth.
On June 3, 1992, in a letter addressed to petitioners at the
Fort Worth address, the IRS requested that they reschedule the
meeting for the examination of their 1988 and 1989 returns. In a
letter dated June 19, petitioner advised the IRS that he was in a
hospital in Wichita, Kansas, and expected to return to Texas as
soon as his health improved. He asked that the examination be
rescheduled to September 28 or 29, 1992, at the Fort Worth
office. The IRS granted this request; however, 4 days before the
scheduled meeting, petitioner again contacted the IRS and asked
for a postponement. In a letter dated September 24, 1992,
petitioner informed the IRS that he had relocated to Wichita for
employment and requested that the examination be moved to the IRS
office nearest to his new residence at 9100 E. Harry # 2715,
Wichita, Kansas 67207.
On October 7, 1992, the IRS office in Fort Worth sent
petitioners a letter at their Wichita address informing them of
proposed adjustments to their 1988 and 1989 returns, and giving
petitioners 30 days to respond. On October 20, 1992, the Austin
service center received petitioners' 1991 Federal income tax
return listing their residence as the Fort Worth address. In the
occupation box, petitioner wrote "Engineer (Construction Fields),
three different short-term assignments in three locations, away
from home." On November 25, 1992, petitioners met with Virginia
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