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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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Last modified: May 25, 2011