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In the resulting exchange of letters between petitioner and
an IRS examiner in South Bend, Indiana, the IRS requested that
petitioner either (1) provide copies of her filed returns for the
years in issue, or (2) file the requested returns if petitioner
had failed to file them in the past.
Petitioner responded by writing to the IRS contending that
she had filed returns for the years in issue. Petitioner
promised the IRS that she would provide copies of the requested
returns. Later, in a letter dated April 3, 1997, petitioner
informed the IRS examiner in South Bend, Indiana, that she had
sent copies of her "forms and schedules, including 1992, 1993 and
1994 F[orm] 1040X's based on a net operating loss carryback from
the tax year 1995" to the Cincinnati IRS Service Center.
Petitioner purportedly sent the documents to the Cincinnati
Service Center because she "received a similar demand letter from
the Cincinnati Service Center for some of the same information
sought by * * * [the IRS examiner in South Bend, Indiana]".
Despite repeated requests, petitioner did not provide copies
of her tax returns for the years in issue to the IRS office in
South Bend, Indiana. Ultimately, petitioner asked the IRS to
issue a notice of deficiency, and, in a subsequent notice of
deficiency dated February 19, 1998, respondent determined the
deficiencies listed above.
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