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delivered safely to the Court through a diplomatic pouch.
Petitioners delivered their Tax Court petition to the U.S.
Embassy in Mexico City on August 17, 1994. On August 22, 1994,
respondent assessed $181,637 in tax and $60,458.83 in interest
for petitioners' 1990 tax year.
On September 6, 1994, the petition in which petitioners
disputed their 1990 income tax deficiency was filed in the Tax
Court. On October 21, 1994, we granted respondent's motion to
dismiss for lack of jurisdiction because petitioners' petition
was not timely filed.
D. Respondent's Reconsideration of Petitioners' Case
On a date not stated in the record, Dietz asked respondent’s
Los Angeles Appeals office to reconsider the assessment for 1990.
The Appeals office agreed to do so.
Catherine Keenan (Keenan), an Appeals officer for respondent
in Los Angeles, obtained and reviewed the file for petitioners’
1990 tax year sometime between October 21, 1994, and February 1,
1995. Keenan sent a letter to petitioners on December 30, 1994,
inviting them to attend a conference. Petitioner met with Keenan
on February 1, 1995, and gave her all the information he had.
Keenan reviewed petitioners' case. She estimated the basis
for the properties used in the section 1031 exchange. Keenan
sent a written proposed settlement of the case to petitioners on
March 2, 1995. On March 7, 1995, petitioners sent Keenan a
facsimile message in which they acknowledged receipt of the
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