John J. Burke and Vivian Burke - Page 5

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            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.                                                                                  










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