- 10 - Byron Stout, an employee at the processing division at the Service Center. During this discussion Mr. Crabtree requested that Mr. Stout forward the protest letter to respondent's Appeals Office in Nashville, Tennessee. Because the protest letter was not received by respondent's examination division within the designated period, preparation of the notices of deficiency began on March 3, 1994. Notices of deficiency for years 1988 and 1991 were mailed to the Dugans on March 22, 1994. In the notice of deficiency for 1991, the passthrough loss attributable to NTI was disallowed upon the ground that NTI's S corporation election was not effective until January 1, 1993. The notice of deficiency for 1988 disallowed the net operating loss carryback that was generated in 1991 by the passthrough loss. The deficiency notices indicated that if the Dugans took the position that NTI had timely filed a Form 2553 effective for 1991 they could provide as acceptable verification: (1) A certified mail receipt reflecting that the form was timely mailed; (2) a Form 2553 with date stamp acknowledging receipt; or (3) an IRS letter stating that Form 2553 had been accepted. Prior to the issuance of the notices of deficiency, respondent's administrative file did not disclose the receipt of a request for an Appeals conference made by or on behalf of the Dugans. On June 10, 1994, Mr. Crabtree mailed a letter to respondent requesting that the notices of deficiency be rescinded. InPage: 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