- 4 -
a power of attorney, Form 2848, Power of Attorney and Declaration
of Representative, provided certain information and documentation
to respondent.
On December 11, 1987, respondent sent petitioner a 30-day
letter at petitioner’s new address in Romoland, California.4 The
letter proposed changes to petitioner’s 1985 return, including
the complete disallowance of the Schedule C deductions in the
amount of $36,145.
On January 6, 1988, Mr. Davis sent a reply letter to
respondent’s revenue agent in Modesto, California. That letter
stated in part as follows:
I am writing to confirm our telephone conversation of
December 28, 1987. At that time you stated that you
were going to disallow all deductions due to the fact
that the amounts originally claimed could not be
reconciled to the amounts which were documented upon
your audit of my client of [sic] 1985 Form 1040.
I am recommending to my client that we go through the
normal channels of appeal in this matter. We would
first request a conference with your supervisor to
discuss the audit adjustments as you have proposed.
On January 12, 1988, respondent sent Mr. Davis a letter,
enclosing receipts and canceled checks that petitioner and/or Mr.
Davis had submitted to the revenue agent’s group manager in
Modesto, California, on January 12, 1988. Presumably, this
4 On Dec. 29, 1987, petitioner executed Form 488-A, Change
of Address, reflecting Romoland as his new address. It would
appear that petitioner’s change of address had come to
respondent’s attention before petitioner provided formal
notification.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011