- 7 - return the Form 872. In pertinent part, the Form 872 states: “The amount of any Federal Income tax due on any return(s) made by or for the above taxpayer(s) for the period ended September 30, 1994, may be assessed any time before December 31, 1998.” Petitioner did not return the Form 872 or respond to the document request. Instead, petitioner attempted to negotiate restrictions to be incorporated into the Form 872. Revenue Agent Grimes and her supervisors refused to restrict the Form 872 and, on November 20, 1997, no Form 872 having been received by respondent, the notice was issued. By letter dated December 8, 1997, Stephen P. Taylor, Chief, Exam Branch V (apparently, a supervisor of Revenue Agent Grimes), explained respondent’s failure to restrict the Form 872: “Conditions required under the Internal Revenue Manual were not met. We do not restrict statutes or the scope of an examination prior to initiating the examination.” Other documents in evidence establish the following: On October 27, 1997 (the date the examination commenced), Revenue Agent Grimes was examining petitioner’s income tax returns for the 2 taxable years preceding 1994 (the preceding years’ examination). She completed the preceding years’ examination on November 6, 1997. On that date, petitioner was sent a copy of the resulting report (the report). The report shows adjustments with respect to the following items:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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