- 4 - contained a check next to a paragraph thanking the addressee for information sent and advising that the case would be returned to the examination group for evaluation. The letter further advised that “The last day for filing a petition is 12/2/96.” On November 12, 1996, Lester Johnson met with Rebecca Piper, a representative of respondent’s examination group, to discuss the audit of the 1994 tax year. According to Ms. Piper, that meeting had been prearranged as a consequence of a contact by Mr. Johnson for audit reconsideration. During that meeting, Mr. Johnson submitted some canceled checks to substantiate certain deductions taken in 1994. The evidence submitted at that time was insufficient, however, to warrant any change in the prior determination. Mr. Johnson was again advised of the due date for filing of the petition. On or about July 11, 1995, petitioner Lester Johnson submitted to respondent’s Fresno Service Center (the service center) a Form 4361, Application for Exemption from Self- Employment Tax for Use by Ministers, Members of Religious Orders and Christian Science Practitioners. The Form 4361 showed the applicant’s address as 3233 Grand Avenue, Ste N347, Chino Hills, CA 91709 (the Grand Avenue address). On February 2, 1996, the director of the service center responded to Mr. Johnson at the Grand Avenue address denying the application and returning the original form.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011