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transferred the administrative files to Dallas. The
administrative files were received by the Dallas IRS office on
February 10, 1995--3 weeks after they were sent by the El Paso
IRS office. At this point, 16� months remained before the
expiration of the 1991 tax return limitations period.
About 10 months later, the administrative files were noticed
in the bottom of a file cabinet outside the office of the acting
manager of the examination group to which the matter had been
sent. Four months later the acting manager assigned the case to
Ward. At this point, less than 2� months remained before the
expiration of the 1991 tax return limitations period. Ward moved
relatively promptly. Six days later she and petitioners’
representative met to discuss the case. For 2 hours petitioners’
representative answered Ward’s questions. Ward asked for a 1-
year extension of the limitations periods. Petitioners’
representative and Ward orally agreed to a 6-month extension.
Ward had prepared an IDR, and had taken it to the April 23, 1996,
meeting, but did not give the IDR to petitioners’ representative.
Nor did Ward give to petitioners’ representative at this meeting
any other writing specifying for examination particular items
shown on the 1991 or 1992 tax returns. For the next 3 weeks Ward
telephoned petitioners’ representative’s office, but the calls
were not returned. Finally, on June 26, 1996, Ward went to
petitioners’ representative’s office, but he said he would agree
to only a restricted extension. The next day, a notice of
deficiency was issued.
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