Paul K. Hanashiro - Page 3




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          interest of $9,874.21, and an estimated tax penalty of $8,209.03.            
          The examination report for 1995 lists a balance due of                       
          $11,504.45, comprising tax of $7,780 (deficiency of $54,085 less             
          prepayment credits of $46,305), interest of $1,636.57, and an                
          estimated tax penalty of $2,087.88.  A third examination report              
          dated January 27, 1998 (which included the proposed disallowance             
          of the prepayment credits allowed in the earlier examination                 
          reports for 1994 and 1995), states that petitioner owes balances             
          of $184,941.22, $125,983.69, and $110,688.75 for taxes, interest,            
          and estimated tax penalties for 1994, 1995, and 1996,                        
          respectively.                                                                
               In late April 1998, counsel for petitioner wrote to Nancy L.            
          Jones at respondent's Kansas City Service Center to request that             
          the notices of deficiency for 1994 and 1995 be withdrawn on the              
          grounds that the notices were arbitrary and inaccurate.  Ms.                 
          Jones was listed as the "Person to contact" in the notices of                
          deficiency.                                                                  
               On April 28, 1998, petitioner filed a tax return for 1994 in            
          which he claimed a refund of $8,310.57.                                      
               On May 4, 1998, counsel for petitioner wrote to Revenue                 
          Agent Tom Spolrich in Chicago, who had recently contacted                    
          petitioner, to request the withdrawal of the notices of                      
          deficiency for 1994 and 1995.                                                







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