- 3 - Respondent, through his District Director, commenced an audit of petitioners’ 1994 and 1995 taxable years about June 1997. In connection therewith, the District Director requested certain information; petitioners ultimately provided some, but not all, of this information to the District Director. The District Director concluded the audit on July 2, 1998, proposing certain upward adjustments to petitioners’ income. On that date, the District Director also mailed to petitioners two 30-day letters (one for 1994 and one for 1995) listing proposed upward adjustments of $5,675 and $12,493 to the respective years’ income. The 30-day letter invited petitioners to request an administrative appeals conference to discuss these proposed adjustments, providing: “IF YOU * * * wish a conference with the Regional Office of Appeals [Appeals], YOU MUST LET US KNOW within 30 days.” The 30-day letter explained the procedures for requesting a conference with Appeals. Petitioners never requested a conference with Appeals for either year. Nor did they ever deliver to respondent a written protest as to the District Director’s conclusions set forth in the 30-day letters. On March 19, 1999, respondent issued the notices of deficiency to petitioners. As to 1994, respondent determined that petitioners were liable for a $5,383 deficiency and a $1,070.60 accuracy-related penalty under section 6662(a). As toPage: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011