Joseph W. Evans, Jr. and Mildred S. Evans - Page 4




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               are liable for a accuracy related penalty pursuant to                  
               I.R.C. � 6662(a) in the amount of $534.00.  You had                    
               provided documentation regarding these areas and the                   
               examiner made adjustments to the amounts listed in the                 
               notice of deficiency accordingly.  Enclosed please find                
               a Statement of Income Tax Changes prepared on the basis                
               of the amounts allowed by the Examiner in the district.                
               Additionally, we have enclosed a Statement of Account                  
               for the tax year 1992.                                                 
                    If you no longer wish to proceed with a trial, I                  
               have enclosed a set of decision documents which contain                
               the revised liability determined by the examiner.  The                 
               amount now determined to be owed is considerably less                  
               than the original proposed liability.  Please review                   
               the Statement of Income Tax Changes and the proposal                   
               for settlement.  If you agree with the settlement,                     
               please sign the original and one copy of the decision                  
               and return them in the envelope provided.  The third                   
               copy is for your file.                                                 
                    If you no [sic] do not wish to settle the case                    
               with the amounts determined by the examiner, please                    
               contact our office.  It is important that we begin the                 
               stipulation process soon in order to comply with the                   
               Tax Court's rules.  In the meantime, we will begin                     
               drafting a Stipulation of Facts and will forward it to                 
               you for you to review.                                                 
               The decision document referred to in the aforementioned                
          letter proposed an agreement to a deficiency in tax in the amount           
          of $2,670 and an accuracy-related penalty in the amount of $534.            
               On February 20, 1996, respondent met with petitioners.  On             
          February 21, 1996, petitioner Joe Evans wrote to respondent the             
          following:                                                                  












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