Andrea Cipriano - Page 5




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          The record does not reflect whether or when petitioner received             
          the installment payments that were due from her ex-spouse under             
          the agreement in 1997 and 1998.                                             
               On her 1994, 1995, and 1996 timely filed Federal income tax            
          returns, petitioner did not report as interest income any of the            
          above payments received from her ex-spouse.                                 
               By letter dated July 2, 1998, respondent notified petitioner           
          that respondent wished to examine petitioner’s 1995 and 1996                
          Federal income tax returns.  In the letter, respondent proposed a           
          meeting for July 30, 1998, between respondent’s audit                       
          representative and petitioner relating to petitioner’s 1995 and             
          1996 Federal income taxes.  At petitioner’s request, the meeting            
          was held on July 30, 1998, in Parsippany, New Jersey, the                   
          location of petitioner’s employment.                                        
               Petitioner and respondent’s audit representative met again             
          in August of 1998 to discuss petitioner’s 1995 and 1996 Federal             
          income taxes.  During that meeting, petitioner and respondent’s             
          representative failed to reach an agreement on various                      
          adjustments that had been raised.  After this meeting, in August            
          of 1998 or thereafter, petitioner’s 1994 Federal income tax                 
          return was opened for examination by respondent.  Another meeting           
          was scheduled for September 16, 1998, between petitioner and                
          respondent’s audit representative to discuss further petitioner’s           
          1995 and 1996 Federal income taxes and to discuss petitioner’s              






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