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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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Last modified: May 25, 2011