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responsibility for the ongoing examination of petitioners' 1993
income tax return had been reassigned. Ms. Hatley explained
that, because of the press of other business, she had not had the
opportunity to review the material that petitioners had
previously furnished. Ms. Hatley suggested that petitioners
write to Ms. Fenton, the "contact person" specified in the notice
of deficiency, and request further consideration of their case by
Ms. Hatley.
By letter dated September 6, 1996, petitioners wrote to Ms.
Fenton and requested that their file be transferred to Ms. Hatley
for Ms. Hatley's further consideration. The penultimate
paragraph of petitioners' letter stated as follows:
The basis for this transfer of file is my request and
Lana's agreement to a further interview. We believe
that she now has all the information she requires in
order to perform her audit of 1993 and our meeting will
conclude the open issues.
Petitioners' request was granted, and Ms. Hatley undertook
to consider further petitioners' case. Accordingly, on September
19, 1996, and at Ms. Hatley's request, petitioners faxed various
documents to Ms. Hatley for her consideration. Communication
between petitioners and Ms. Hatley continued through October
1996.
On the basis of their telephone conversation with Ms. Hatley
on or before September 6, 1996, as well as Ms. Hatley's agreement
to consider further their case, petitioners believed that the
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