Charles T. and Joan B. Phillips - Page 5

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               Also in the spring of 1992, Evelyn Napolitano (Revenue Agent           
          Napolitano), another revenue agent in Florida, contacted peti-              
          tioners regarding the collection of employment tax from peti-               
          tioner's professional corporation, Charles T. Phillips, P.C.                
          Around May 6, 1992, petitioners informed Revenue Agent Napolitano           
          of their impending move to the Bayou Glen address.  Based on                
          petitioner's statements to Revenue Agent Morgan and Revenue Agent           
          Napolitano, petitioners' address was changed to the Bayou Glen              
          address on the Internal Revenue Service's computer records by               
          September 1992.                                                             
               In June 1992, after petitioners moved to the Bayou Glen                
          address, the CPMC audit was transferred from Revenue Agent Morgan           
          to Revenue Agent Myers.  Also in the spring of 1992, the employ-            
          ment tax collection matter was transferred to Revenue Officer               
          Herma Mills (Revenue Officer Mills).  Neither Revenue Agent Myers           
          nor Revenue Officer Mills was aware at any time during the years            
          in issue of each other's investigation of these tax liabilities.            
               On August 4, 1992, Revenue Officer Mills informed petition-            
          ers by a certified letter addressed to Charles T. Phillips, P.C.,           
          at the Bayou Glen address, of the Internal Revenue Service's                
          intention to make a levy against the assets of that corporation             
          to satisfy unpaid employment tax liabilities for all of 1990 and            
          the first 3 quarters of 1991.  Petitioner signed the return                 
          receipt for this letter on August 7, 1992.                                  






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