- 9 - On January 20, 1994, two separate letters (the 30-day letters) with accompanying examination reports proposing changes to their 1988 and 1991 joint Federal income tax returns were mailed to the Dugans. The proposed changes resulted primarily from the disallowance of the passthrough loss from NTI in 1991 upon the ground that a valid S corporation election had not been filed by the corporation for that year. The 30-day letters listed Toni Williams as the contact person and were signed by Connie Hailey, Chief, Service Center Examination Branch. Responses to the 30-day letters were due on or before Tuesday, February 22, 1994. At some point prior to February 18, 1994, Ms. Tidwell referred the Dugans to Larry D. Crabtree, attorney, for assistance in connection with the proposed adjustments made in the 30-day letters. Mr. Crabtree responded to the 30-day letters by letter dated February 22, 1994 (the protest letter), which was sent by certified mail to the "District Director, Memphis Service Center". In the protest letter, Mr. Crabtree requested an Appeals conference to discuss the proposed adjustments set forth in the 30-day letters. In addition, Mr. Crabtree contended that the relevant Form 2553 had been timely mailed so that NTI's S corporation election should have been effective for its 1991 taxable year. In a telephone conversation that took place on or about March 17, 1994, Mr. Crabtree discussed the protest letter withPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011