- 6 - In 1992, during the audit of petitioner's 1988 income tax return, respondent's revenue agent requested copies of petitioner's 1989 and 1990 returns. In April 1992, petitioner gave photocopies of those returns to the agent. At that time, the agent believed that petitioner had previously filed the returns with the Internal Revenue Service. Petitioner gave the agent no indication otherwise. Both returns had been signed before they were photocopied, and neither return bore petitioner's original signature. In September or October 1992, the agent began an examination of petitioner's 1989 and 1990 returns. In due course, the revenue agent found that the Internal Revenue Service had no record of having received either the 1989 or 1990 return. The agent notified petitioner, by letter dated November 6, 1992, that the photocopied returns would be processed as delinquent returns once the agent received a copy of each return that bore petitioner's original signature. The agent's letter states as follows: As per our telephone conversation yesterday, I will process the previously submitted copies of your 1989 & 1990 1040 income tax returns as delinquent returns since our records do not indicate receipt of the aforementioned at the service centers. However, before I can process the copies I need them to have original signa- tures. Please provide same above the copied signature (also date) and return them to me soPage: 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