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letter dated January 20, 1993, respondent advised petitioners
that their case was being forwarded to respondent’s Appeals
Office for consideration.
On February 22, 1993, petitioners’ case was received in the
Birmingham, Alabama, Appeals Office and assigned to Appeals
officer Dennis Smith, who worked out of respondent’s Jackson,
Mississippi, suboffice. Shortly thereafter, Smith mailed
petitioners two letters advising them that the case had been
referred to the Appeals Office and requesting they schedule an
appointment. On April 21, 1993, Smith met with petitioner wife
as scheduled. On November 12, 1993, Smith mailed petitioners a
letter asking their consent to extend indefinitely the period of
limitations to assess tax with respect to both taxable years 1989
and 1990. On November 20, 1993, petitioners executed a Form 872-
A, Special Consent to Extend the Time to Assess Tax. On
November 30, 1993, Smith mailed petitioners a letter transmitting
a copy of the executed Form 872-A.
On June 23, 1994, after attempting unsuccessfully to settle
the case, respondent mailed petitioners a notice of deficiency
from the Birmingham Appeals Office. In the notice, respondent
determined that petitioners were liable for deficiencies of
$14,088 and $16,610, and accuracy-related penalties of $2,818 and
$3,322, for taxable years 1989 and 1990, respectively. The
notice was sent by certified mail to petitioners’ last known
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