- 7 - Notice of Deficiency On February 15, 1996, respondent issued a notice of deficiency to petitioner. The notice stated that upon conducting a bank deposit analysis of petitioner's City National Bank accounts, the Commissioner determined that petitioner failed to report taxable income of $167,693 in 1987, $85,204 in 1988, and $259,957 in 1989. On May 10, 1996, petitioner filed a petition with this Court, denying that she had any unreported taxable income during the years in issue. In the answer filed on June 24, 1996, respondent asserted that some of the bank deposit sources were verified. Settlement Negotiations In late July 1996, Mr. Guterman received a letter from Appeals Officer Steve Millang requesting a settlement conference for August 12, 1996. The meeting was never scheduled due to the fact that Mr. Guterman was awaiting the result of a bank deposit analysis conducted by Steve Slatkin, an expert retained by Mr. Guterman. Additionally, Mr. Guterman was awaiting the production of additional bank deposit documents in the IRS's possession. Appeals Officer Millang forwarded the additional documents to Mr. Guterman. On or about September 24, 1996, Mr. Guterman wrote District Counsel Linas Udrys and requested the latter to obtain additional bank deposit information from the CID. On November 5, 1996, Appeals Officer Millang wrote Mr. Guterman advising that the CIDPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011