Carolyn S. Eifert, A/K/A Sue Armstrong - Page 19

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          is nothing in the record to suggest why respondent could not have           
          contacted the FDIC in order to determine the basis on which the             
          Forms 1099-G were issued given the dubious nature of such forms.            
               Further, respondent issued the notice of deficiency after              
          only one attempt to contact petitioner.  We again take note of              
          the fact that the notice determined a million dollar adjustment             
          to petitioner's income.  As a consequence of this million dollar            
          adjustment, the notice determined a deficiency in petitioner's              
          income tax in the amount of $377,365, and additions to tax under            
          sections 6651(a) and 6654(a) in the amounts of $94,341.25 and               
          $15,809.68, respectively.  The notice also advised petitioner               
          that she was liable for interest (calculated through December 20,           
          1995) in the amount of $74,934.  Thus, according to the notice,             
          the total amount due from petitioner (calculated through December           
          20, 1995) was $562,450.  Given a liability of this magnitude, and           
          in view of the dubious nature of the Forms 1099-G, we question              
          whether respondent should have issued the notice of deficiency              
          after making only one attempt to contact petitioner.                        
               Indeed, we take note of the fact that respondent originally            
          proposed the liability of $562,450 in the 30-day letter that was            
          sent to petitioner in November 1995.  Again, given the magnitude            
          of such liability, and in view of the dubious nature of the Forms           
          1099-G, we question whether respondent should have even proposed            








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