- 5 -
On May 22, 1995, Revenue Agent Kropp mailed a notice to
petitioner scheduling an appointment for June 15, 1995. Neither
petitioner nor a representative on her behalf appeared at the
meeting.
Revenue Agent Kropp mailed a "30-day letter" dated September
5, 1995, to petitioner, along with his examination findings of
unreported income for the years in issue. The 30-day letter stated
that if petitioner disagreed with the findings, she could either:
(1) Mail additional evidence or information; (2) request a
discussion of the findings with the examiner; or (3) discuss her
position with a group or senior manager. The letter further stated
that if petitioner did not want to take any of these courses of
action, she could either call or write the IRS within 30 days from
the date of the letter.
On September 25, 1995, petitioner contacted Revenue Agent
Kropp and informed him that she disagreed with the findings in the
30-day letter and would provide additional information to him.
On October 10, 1995, not having received any information from
petitioner, Revenue Agent Kropp closed petitioner's case as
"unagreed" and forwarded it to the appropriate section of the IRS
for issuance of a notice of deficiency.
On October 26, 1995, petitioner retained Barry L. Guterman to
represent her in the tax matters. On November 6, 1995, Mr.
Guterman informed Revenue Agent Kropp of his retention by
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011