Richard Dundore and Virginia D'Anna-Dundore - Page 3




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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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