- 3 -
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the notices of deficiency for 1994 and 1995 be withdrawn on the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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011