- 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