- 4 - for filing, on October 15, 1992, and October 15, 1993, respectively, and were received at the Austin, Texas, Service Center on October 19, 1992, and October 18, 1993, respectively. In October 1994, a revenue agent with the IRS office in El Paso telephoned petitioners and indicated that there would be an examination of petitioners’ 1991 and 1992 tax returns. On November 14, 1994, petitioners’ representative wrote to the revenue agent, asking that the location of the examination be transferred to Dallas, Texas. Petitioners’ representative stated that his office is in Dallas and that he “has all of the books, records, and source documents that will be necessary to complete a 1991 and 1992 examination.” The revenue agent did not send correspondence to petitioners identifying specific matters to be addressed in the examination. In connection with the transfer of the examination and related files to Dallas, the revenue agent asked petitioners to consent to extending to June 30, 1996, the period of limitations for assessment of 1991 income tax. To accomplish this, a Form 872 was executed by petitioners’ representative on December 20, 1994, by petitioners on December 21, 1994, and by respondent on January 5, 1995. The period of limitations date for 1992 remained October 15, 1996. The IRS administrative files relating to 1991 and 1992 were transferred from El Paso on January 20, 1995, and received in the Dallas IRS office on February 10, 1995. The responsibility forPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011