- 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 knownPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011