Larry D. & Gail Scott - Page 8




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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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