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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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