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arrange a mutually satisfactory conference date. In a letter
dated September 19, 1989, Appeals Officer Holder wrote
petitioners to inform them that she had scheduled a conference
for October 11, 1989, with respect to their 1985, 1986, and 1987
tax years. After petitioners failed to respond to this letter,
Appeals Officer Holder wrote to petitioners on October 12, 1989,
scheduling another conference date for October 24, 1989. On
October 20, 1989, Mrs. Lavallee contacted the office of Appeals
Officer Holder to advise her that petitioners would be out of
town for 3 to 4 weeks. On March 20, 1990, after petitioners had
failed to contact respondent requesting another conference date,
respondent issued a notice of deficiency. In the notice,
respondent determined the following deficiencies and additions to
tax:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6653(a)(1) Sec. 6653(a)(2)
1985 $868 $317 $244 50 percent of
the interest
due on $868
Additions To Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6653(a)(1)(A) Sec.
6653(a)(1)(B)
1986 $3,038 $665 $296 50 percent of the
interest due on
$3,038
1987 4,104 843 261 50 percent of the
interest due on
$4,104
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