- 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