- 5 -- 5 - ordinary and necessary to your business, we have disallowed the amount shown." On February 3, 1995, respondent sent a 30-day letter to petitioners proposing that petitioners were liable for a $14,939 deficiency in 1993 income tax and a $2,988 penalty under section 6662(a).4 Respondent issued the subject notice of deficiency on April 20, 1995, reflecting her determination of a deficiency and penalty in the same amounts as proposed in the 30-day letter. The deficiency and penalty shown in the notice of deficiency are primarily due to the adjustments mentioned above. Before the notice of deficiency was issued, petitioners did not present respondent with any substantiation for the disallowed deductions or any explanation concerning the fact that the $21,025 of wages shown on the Form W-2 from EP Management Services, Inc., was not includable in their 1993 gross income. On June 12, 1995, petitioners' counsel, Stuart S. Lipton, mailed a letter to an Internal Revenue employee at an Internal Revenue office in Los Angeles, California. This letter states: Dear Patty: This is to confirm that there will be a meeting in Room 4336 in the offices of the IRS at 300 North Los Angeles Street at 12:45 p.m. on June 27, 1995, at which Charles Thiras, accountant for the taxpayer, will present documentary evidence to support the validity of 4 Petitioners claim that this 30-day letter was the first notice that they received alerting them that respondent was auditing their 1993 Federal income tax return.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011