- 3 - A. The 1992 Tax Year Audit On August, 29, 1994, petitioner filed his 1992 Federal income tax return using the following mailing address: 67 Rosewood Drive, Atherton, California 94027 (the Atherton address). On June 14, 1995, respondent mailed petitioner a letter informing him that his 1992 Federal income tax return had been selected for audit. Respondent’s audit letter requested that petitioner contact respondent within 10 days to arrange an interview and bring to the interview complete records concerning specified claimed deductions. On July 31, 1995, petitioner called respondent and arranged an initial interview. Petitioner failed to attend the interview. On August 29, 1995, respondent mailed a notice of proposed deficiency (30-day letter) to petitioner at the Atherton address. On September 25, 1995, petitioner faxed to respondent a handwritten letter informing respondent that he had moved to Beijing, China, and that he needed additional time to furnish the requested information. Petitioner further stated that he was unable to find his business records and that he needed more time to recreate them using his check register and credit card statements. Petitioner asserts that he responded to respondent’s audit letter by delivering a letter and three boxes of documents to respondent on November 30, 1995. Petitioner contends that thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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