- 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 byPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011