- 6 - (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 andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011