16
The notice of deficiency stated that a report had been
"furnished to the tax matters partner (person)". This statement
was in error in that respondent's agent had not provided the
report to petitioner, there was no tax matters partner since
Eagle was an S corporation, and Eagle had not named a tax matters
person on its 1990, 1991, and 1992 tax returns, Forms 1120S.
On December 22, 1994, petitioner filed his petition in this
case.
This case had been calendared for an earlier trial session
in Atlanta, Georgia. Respondent moved for a continuance. We
granted respondent's motion.
E. Respondent's Agent's Modification of and Testimony About the
30-Day Report
On October 15, 1996, respondent's counsel sent some
documents to petitioner's counsel to include in the stipulation
of facts. One of the documents respondent sent was a copy of the
revenue agent's June 25, 1993, report, described in paragraph I-
C, above.
Petitioner discovered shortly before trial that the copy of
the June 25, 1993, report which respondent sent to petitioner
differed from the original version in that the chart on page 6 of
the report included a column for 1992, as follows:
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