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involve a home and an address at 1222 Grand Avenue, San Rafael,
California (the Grand Avenue address).
Background
Petitioners, husband and wife, filed their 1982 through 1991
Federal income tax returns with the Internal Revenue Service
(IRS) Center at Fresno, California, listing the Grand Avenue
address on each of these returns. Petitioners have maintained a
residence at this address since 1961. Sometime in 1988,
respondent began an audit of petitioners' 1982 through 1987
returns. During the course of the audit, which continued until
the latter part of 1990, the revenue agent assigned to the audit
telephoned, interviewed petitioners, and examined their records
at the Grand Avenue address. As part of the audit, the revenue
agent also received letters from and spoke with petitioners'
attorneys to verify the purpose and amount of legal expenses
claimed on petitioners' returns for legal services these
attorneys had provided petitioners. These attorneys, however,
did not represent petitioners in connection with the audit of
petitioners' returns. In August 1990, the revenue agent made
proposed adjustments to petitioners' returns. By letter dated
November 10, 1990, petitioners protested these proposed
adjustments. Thereafter, the Appeals Division of the IRS took
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