- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011