Patricia Williams, a.k.a. Patricia Richardson, a.k.a. Tish Martinson - Page 5

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               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                    





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