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petitioners by letter that there was no basis for changing the
proposed adjustments made in the revised RAR. He advised
petitioners of their options to extend the period of limitations
or litigate the matter in United States Tax Court or District
Court. The case was forwarded to the Birmingham Appeals Office
with Mr. Smith’s recommendations regarding the proposed
adjustments. On November 30, 1994, respondent issued a notice of
deficiency for the 1989 and 1990 tax years based upon the
proposed adjustments made in the revised RAR. In addition, in
the notice of deficiency, respondent determined that for each
year petitioners were liable for an accuracy-related penalty
under section 6662(a).
On February 27, 1995, a petition for the redetermination of
the deficiencies determined in the above-mentioned notice of
deficiency was timely filed, pro sese (the deficiency
proceeding). Petitioners designated New Orleans as the place of
trial in the deficiency proceeding. Initially, the deficiency
proceeding was assigned to one of respondent’s attorneys in
Birmingham, Alabama. On May 8, 1995, after the petition had been
answered, the deficiency proceeding was transferred to senior
attorney Emile L. Hebert III (Mr. Hebert), one of respondent’s
attorneys located in New Orleans.
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