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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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