- 3 -
with the Superior Court on August 30, 1991, "Child Support Paid
by Garry Bettencourt" summaries for the year 1993, and wage stubs
showing amounts paid to petitioner by Medallion Mortgage Company
during 1993.
On May 18, 1995, respondent sent petitioners a 30-day letter
proposing to disallow the claimed alimony deduction.
In response to the 30-day letter, on June 3, 1995,
petitioners' counsel, Mr. Read, mailed to respondent a five page
letter protesting respondent's proposed income tax examination
changes. He forwarded with his letter a power of attorney, Form
2848, and requested that petitioners' return be accepted as
filed. In the event that respondent would not accept the return
as filed, Mr. Read requested that his letter be treated as a
formal protest and that the matter be referred to the Appeals
Office for hearing. By letter dated June 14, 1995, Mr. Read sent
to respondent an original Form 2848, signed by petitioners.
On June 27, 1995, respondent sent Mr. Read a letter
proposing the same adjustments to petitioners' 1993 return as
were proposed in the May 18, 1995, 30-day letter.
During the summer months of 1995, correspondence was
exchanged between Mr. Read and respondent through which
respondent sought additional information about the alimony issue.
A statutory notice of deficiency for 1993 was mailed to
petitioners on February 7, 1996. Petitioners filed their
petition in docket No. 7950-96 with the Court on April 26, 1996,
and respondent filed an answer on May 21, 1996; the case was then
referred to respondent's Appeals Office.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011