- 5 - funds from the Burke Insurance Agencies by several of Mr. Burke's employees. Respondent also determined an addition to tax for delinquent filing of the returns in issue. The 30-day letter also stated as follows: IF YOU DO NOT AGREE and wish a conference with the Office of the Regional Director of Appeals, you MUST LET US KNOW within 30 days. * * * * * * * An appeals officer, who has not examined your return previously, will review your case. The appeals office is independent of the district director and resolves most disputes informally and promptly. By going to the appeals office, you may avoid court costs, resolve the matter sooner, and prevent interest from compounding. * * * On May 20, 1992, respondent received another Form 2848 Power of Attorney from Mr. Silver, which appointed Mr. Silver and Robert Nicolai, C.P.A., as petitioners' representatives for the taxable years 1985 through 1989. Both petitioners had signed this form on May 11, 1992. On June 16, 1992, Mr. Silver informed respondent that petitioners would not be filing a protest. Neither petitioners nor Mr. Silver ever requested an Appeals Office conference with respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011