Girish and Nalini G. Patel - Page 3

                                          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