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copy to the first representative listed on line 2
unless you check one or more of the boxes below.
Although the first of three boxes referred to in line 7 provided
an election under which all original notices would be sent to
petitioners' attorney-in-fact, petitioners did not check the
box.
Respondent received petitioners' Form 2848 on May 21, 1997.
On June 2, 1997, respondent's agent left a recorded
telephone message for Mr. Pratesi reminding him of the need to
respond further to the 30-day letter. Mr. Pratesi did not
respond to the message, nor did he respond further to the 30-day
letter.
On September 16, 1997, respondent mailed a notice of
deficiency to petitioners. In the notice, respondent determined
a deficiency in petitioners' Federal income tax for 1994 in the
amount of $27,675, as well as an addition to tax under section
6651(a)(1) in the amount of $6,918.75 and an accuracy-related
penalty under section 6662 in the amount of $5,535.
The notice of deficiency was mailed to petitioners at the
Guilford address; i.e., the address listed by petitioners on
their income tax returns for 1994 and 1995.2 Respondent did not
mail a copy of the notice of deficiency to Mr. Pratesi.
2 It appears that petitioners' income tax return for 1996
was not filed before the notice of deficiency was mailed.
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Last modified: May 25, 2011