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petitioners’ 1989 and 1990 tax years. Respondent determined that
petitioners had substantial amounts of unreported income for both
1989 and 1990 as a result of respondent's shifting income from
their closely held business entities to petitioners personally.
Respondent also disallowed two dependency exemptions for 1989 and
1990, as well as all of petitioners' claimed itemized deductions,
rental expenses, and depreciation deductions for 1989 and 1990
for lack of substantiation. Additionally, respondent determined
that petitioners were liable for self-employment taxes and
asserted an accuracy-related penalty under section 6662(b)(1).
Petitioners filed a petition on May 28, 1993, challenging
respondent's determinations. The case was assigned docket No.
10789-93. Respondent thereafter filed an answer.
After the case was docketed, the IRS Appeals Office at
Miami, Florida, on July 6, 1993, contacted petitioners by letter
and advised that they would soon be contacted by an Appeals
officer for a conference. That letter suggested to petitioners
that they contact the Appeals Office either in writing or by
telephone if they had any questions concerning their case.
Petitioners did not respond to this letter. On November 30,
1993, an Appeals officer contacted petitioners by letter and
suggested a meeting on January 24, 1994, at Ft. Myers, Florida,
where petitioners resided. Petitioners responded to this letter
on December 24, 1993, agreeing to the meeting with the Appeals
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