- 4 - of attorney authorized Mr. Silver to represent both Mr. Burke and petitioner in respondent's audit. Mr. Silver and respondent's examining agents met on July 31, 1991, and February 11, 1992, and had several telephone conversations prior to May 1, 1992. There is no evidence of any discussion regarding the purported joint filing status of the returns. During the audit process, respondent served summonses upon various banks where petitioners had their business and personal accounts. Pursuant to section 7609(a)(2), respondent sent a certified letter to the account holder(s) within 3 business days of the issuance of the summonses to notify the account holder(s) of the existence of the summonses. On May 15, 1992, respondent issued to petitioners a Letter 950 (30-day letter),4 which proposed the following adjustments: Addition to Tax Year Deficiency Sec. 6651(a)(1) 1985 $14,752 $4,523 1986 142,690 35,781 1987 476 233 Respondent disallowed deductions for losses allegedly incurred by Ard Rhei, Inc., an S corporation owned by Mr. Burke, and deductions for losses resulting from the alleged embezzlement of 4Respondent also sent a copy of the 30-day letter to Mr. Silver.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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