Robert M. and Paulette G. Maddox - Page 4

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            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 for                             




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