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examining petitioners’ income tax returns was assigned to Dallas
IRS Examination Group 1432 on February 16, 1995. There remained
16� months before the limitations period for 1991 would expire.
In mid-December 1995, a revenue agent in Dallas saw the
administrative files for petitioners’ case, together with those
for 16 other cases, in the bottom of an extra file cabinet
outside the acting manager’s office. There remained 6� months
before the limitations period for 1991 would expire.
Finally, on April 17, 1996, petitioners’ case was assigned
by the acting manager to a revenue agent, Julie Ward, hereinafter
sometimes referred to as Ward. Ward’s manager instructed her to
secure extensions of the limitations periods and, if she could
not do so, then she was to “write-up and disallow issues and send
to 90-Day.” There remained 10� weeks before the limitations
period for 1991 would expire.
The April 23, 1996, Meeting
On April 18, 1996, Ward telephoned petitioners’
representative, and left a message in order to set up a meeting.
She called again on April 19. Petitioners’ representative
returned the April 19 telephone call, but Ward was not available.
Ward left another message for petitioners’ representative that
afternoon.
Ward finally reached petitioners’ representative by
telephone on April 22, and asked for extensions of the
limitations periods. Petitioners’ representative expressed
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