Mary Lee Sharer - Page 9

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          petitioner itemized deductions in excess of those allowed in the                   
          notice of deficiency.                                                              
                On March 19, 1995, petitioner's attorney provided more                       
          information to respondent in response to the March 3, 1995,                        
          letter.  Based on this documentation, respondent, in a letter                      
          dated March 22, 1995, conceded additional income adjustments and                   
          the substantial understatement penalty under section 6661.  In                     
          the same letter, respondent sent copies of a proposed stipulation                  
          settlement.                                                                        
                By letter dated March 29, 1995, respondent's Appeals Officer                 
          confirmed by letter to petitioner's attorney a basis for                           
          settlement of the case for 1988 and included an audit statement                    
          reflecting the settlement and a decision to be filed with the                      
          Court.  The decision was signed by the parties and filed with the                  
          Court as a Stipulation of Settlement in view of petitioner's                       
          simultaneous filing of the motion for litigation costs.  Rule                      
          231(c).                                                                            
                With respect to the 1989 tax year, petitioner was first                      
          informed by letter dated December 8, 1992, that her 1989 return                    
          would be examined.  Attached to that letter was an IDR requesting                  
          petitioner to provide certain information that included bank                       
          records and information on nontaxable income.  On December 18,                     
          1992, the IRS agent assigned to the case met with petitioner's                     
          attorney to discuss some of the issues in the case.  However,                      





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