- 4 - 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:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011