- 3 - $35,138.60. The notice of deficiency included an explanation of the adjustments which stated that respondent had disregarded petitioners' "Personal Dental Trust" as a sham and increased petitioners' business income in an amount equivalent to the net income of the trust. The notice of deficiency correctly stated that the last day to file a petition with the Tax Court was July 7, 1999. Respondent mailed the notice of deficiency to petitioners at the Spokane address. Respondent did not mail a copy of the notice of deficiency to White. Petitioners admit that they received the notice of deficiency on or about April 12, 1999. Petitioners did not attempt to contact White or take any other steps in response to the notice of deficiency. White was aware that the 3-year period of limitations on assessments respecting petitioners' 1995 tax year was due to expire on April 15, 1999. Although White was expecting to receive a copy of the notice of deficiency, he waited until early July to contact petitioners to ask whether they had received the notice. When petitioners informed White that they had received the notice of deficiency but had misplaced it, White attempted to contact the revenue agent who had conducted petitioners' examination to obtain information regarding the notice. He was told that the revenue agent was away from thePage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011