Norman E. Duquette, Inc. - Page 6




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               (b)  The notice of deficiency is arbitrary and                         
               erroneous, and is not based on any ligaments of fact.                  
               Moreover, the notice of deficiency amounts to a naked                  
               assessment without foundation whatsoever.                              
               B.  Facts                                                              
               Documents in evidence establish the following:  On                     
          October 27, 1997, Pat Grimes, a Revenue Agent employed by                   
          respondent, commenced an examination (the examination) of the               
          1994 tax return.  On that date, Revenue Agent Grimes sent to                
          petitioner two letters and a request for documents.  The first              
          letter informs petitioner that the 1994 tax return has been                 
          assigned to Revenue Agent Grimes for examination.  It also states           
          that she needs additional information to verify certain items on            
          that return.  The request for documents (document request)                  
          contains a specific and comprehensive list of documents,                    
          including documents substantiating the following items with                 
          respect to the 1994 tax year:                                               
               1.  Year end wages accrued but not paid to shareholder                 
               2.  Supplies                                                           
               3.  Professional Services                                              
               4.  Rent expense                                                       
               5.  Automobile expenses and depreciation                               
               Travel expenses:                                                       
               a.  Meal expenses                                                      
               b.  Hotel expenses                                                     
               c.  Airplane tickets                                                   
          The second letter informs petitioner that the limitation period             
          for the assessing of additional tax for the 1994 tax year will              
          expire soon, encloses a Form 872, Consent to Extend the Time to             
          Assess Tax (Form 872), and requests that petitioner sign and                





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