Edgar and Doris Brown - Page 3




                                        - 3 -                                         
          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                






Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011