2 At the time their petition was filed, petitioners resided in Houston, Texas. References to petitioner are to Girish Patel. The Internal Revenue Service, Austin, Texas, Service Center (IRS) mailed a letter (30-day letter) to petitioners on September 25, 1996, proposing changes in their 1994 income tax return. On the schedule attached to the 30-day letter, respondent increased taxable income by $7,161, resulting in an increase of $1,072 in petitioners’ 1994 tax liability. The adjustments were (1) $7,146 of additional interest income from two accounts at NationsBank of Texas, and (2) $15 of additional wage income. Respondent’s adjustments were based upon a comparing of the amounts reported on petitioners’ Federal income tax return for wages and interest with Forms W-2 and Forms 1099 received from the payors. The 30- day letter stated: If you don’t agree with the proposed changes on page 2: - Check box B on the last page of this notice, - Enclose a signed statement explaining why you disagree, - Include any supporting documents you wish us to consider, and - Use the envelope enclosed to return the last page of this notice with your statement and documents. Please include a telephone number, including an area code, and the best time to call you. The letter stated that if the IRS did not receive a response within the 30-day period, a notice of deficiency would be issued. Petitioners would be able to contest the notice of deficiency in Court. Petitioners did not respond to the 30-day letter, nor did they request an Appeals Office conference.Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011