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On May 26, 1998, petitioner filed tax returns for 1995 and
1996 claiming refunds of $15,020.97 and $15,677.41, respectively.
In a letter to petitioner dated June 3, 1998, Revenue Agent
John Mayer stated:
The purpose of this letter is to inform you that your
case has been changed from status 24 (90 Day) to status
12 (under examination). If you have any questions, you
can reach me at [telephone number omitted].
On June 5, 1998, counsel for petitioner wrote to Revenue
Agent Mayer as follows:
This letter concerns my request for the IRS to withdraw
the Notices of Deficiency dated March 17, 1998 for [the
1994 and 1995] tax years.
As you may be aware, on April 29, 1998 I wrote Nancy L.
Jones in the Kansas City Service Center requesting that
the notices of deficiency be withdrawn, however, to
date I have not receive a response to my
correspondence.
Your letter dated June 3, 1998 suggests the status of
the above referenced tax returns have been changed from
status 24 (90 Day) to status 12 (under examination) but
does not address my concerns regarding the withdrawal
of the deficiency notices.
Enclosed you should find a copy of my letters to Ms.
Jones and the respective deficiency notices. It is my
understanding that each deficiency notice will be drawn
[sic] no later than Monday, June 8, 1998. I will need
written confirmation that the notices have been
officially withdrawn to avert filing a petition with
the U.S. Tax Court to protect the interests of my
client.
On June 9, 1998, at 3:50 p.m., counsel for petitioner hand-
delivered a petition for redetermination to the Court's petitions
section. The petition, although contesting petitioner's tax
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