3
Respondent mailed a notice of deficiency to petitioners on
December 18, 1996. In the notice, respondent determined a
deficiency in the amount of $1,072 in petitioners’ Federal income
tax for 1994. The deficiency is based on determinations by
respondent as set forth in the 30-day letter which was attached
to the notice.
In their petition, filed on March 17, 1997, petitioners
contested the deficiency and alleged that the interest had been
reported by "someone else", the IRS had the necessary
information, and the motive for the issuance of the notice was
intimidation by the IRS to get to petitioners’ savings account.
However, prior to the filing of the petition, and after the
mailing of the notice of deficiency, correspondence took place
between the parties; namely, petitioner and the IRS Problem
Resolution Officer. On January 4, 1997, petitioner wrote a
letter to the IRS explaining that the interest ascribed to
petitioners was reported on another individual’s income tax
return. In response to petitioner’s letter, the IRS sent letters
dated January 30 and February 13, 1997, requesting the Social
Security number of the individual or a copy of the return on
which the income was reported. This information was again
requested by the IRS in a letter dated February 24, 1997. It
appears this correspondence involved petitioners’ 1988 tax year,
as well as the 1994 tax year.
Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011