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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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