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deficiency relating to petitioners’ 1991 and 1992 income tax
returns.
Petitioners filed a timely petition with this Court on
September 26, 1996.5 Respondent filed a timely answer on
November 21, 1996.
After respondent filed the answer, an Appeals officer and a
revenue agent reviewed the substantiation documentation that
petitioners’ representative provided relating to the notice of
deficiency adjustments. Petitioners’ representative’s first
meeting with the Appeals Officer was on January 23, 1997. The
adjustments were ultimately settled as shown in table 1 for 1991,
and table 2 for 1992.
5 The postmark date is Sept. 24, 1996, the 89th day after
the notice of deficiency was issued. See sec. 7502.
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