Gregorio and Viviana Mankita - Page 5




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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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