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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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