Robert Lloyd - Page 3




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          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 the                






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