St. Joseph Lease Capital Corporation - Page 5

                                        - 5 -                                         
          about September 28, 1993.  Later, Price attempted to expand that            
          examination to include the years in issue.  On several occasions            
          during the course of Price’s examination, she visited offices of            
          petitioner at 6019 Tower Court, Alexandria, Virginia.  Price’s              
          examination of petitioner was closed on or about August 1, 1994,            
          with respect to the years in issue.  Thereafter, a notice of                
          deficiency with respect to the years in issue was prepared by or            
          under the supervision of John Henry, Senior Reviewer, Quality               
          Assurance Branch, Richmond District, Internal Revenue Service,              
          Richmond, Virginia.  On October 6, 1994, three copies of that               
          notice of deficiency (the October 6 notice) were sent by                    
          certified mail, addressed as follows:                                       
                         (1) St. Joseph Lease Capital Corporation                     
                              Post Office Box 19307                                   
                              Alexandria, Virginia 22320                              
                         (2) St. Joseph Lease Capital Corporation                     
                              6019 Tower Court                                        
                              Alexandria, Virginia 22320                              
                         (3) Roger A. Pies, Esquire                                   
                              Suite 800 South                                         
                              601 Thirteenth Street, N.W.                             
                              Washington D.C. 20005                                   
          The first address resulted from a query to the main Internal                
          Revenue Service computer.  The second address was found in the              
          case file and is the address at which Price carried out a portion           
          of her examination.  Roger A. Pies (Pies) is an attorney who                
          represented petitioner during the course of Price’s examination,            
          and the third address is that of Pies.                                      





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  Next

Last modified: May 25, 2011