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On February 9, 1993, Revenue Officer Mills made a field call
to the Brownway address and spoke to the property manager on the
premises. Revenue Officer Mills left a calling card on the peti-
tioners' door. Revenue Officer Mills received no response to the
calling card.
Revenue Officer Mills learned petitioners' telephone number
at the Brownway address by issuing a summons to the manager at
the Brownway address. Revenue Officer Mills received no response
to telephone calls she had made to petitioners. On February 22,
1993, Revenue Officer Mills prepared and submitted to her manager
a report of currently not collectible taxes regarding Charles T.
Phillips, P.C. This report was entered into respondent's
computer system on February 25, 1993. The address shown on the
report was not entered into respondent's computer.
On February 22, 1993, Revenue Officer Mills prepared and
submitted to her manager a Form 4183, Recommendation Regarding
100-percent Penalty Assessment. On the Form 4183, Revenue
Officer Mills listed petitioner's address as the Brownway address
and the address of Charles T. Phillips, P.C., as the Bayou Glen
address. Revenue Officer Mills listed the Bayou Glen address as
the current address for Charles T. Phillips, P.C., because her
records indicated that the current address for the corporation
was the Bayou Glen address. Revenue Officer Mills listed the
Brownway address as petitioner's current address because, as a
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