Lester Johnson and Sherelle D. Brooks-Johnson - Page 4

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          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.                                                              





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