- 6 - I received your revenue agent’s report and cover letter dated October 21, 1997. As we discussed, I do not agree with your audit report and its findings. I believe the tax returns in question were filed accurately. As per your letter, you may then close the case as unagreed and I will appeal the findings in court. On March 18, 1998, respondent mailed to Haas and his wife and to Haas & Associates 30-day letters that reflected the same adjustments that were reflected in the above revenue agent’s reports. Respondent’s 30-day letters explained the protest rights available to Haas and his wife and to Haas & Associates to administratively appeal the proposed adjustments.1 Haas and his wife and Haas & Associates did not file a protest or request a conference with respondent’s Appeals Office with regard to the above proposed adjustments in their Federal income tax liabilities. On June 10, 1998, respondent closed his audit regarding Haas and his wife for 1993 and regarding Haas & Associates for 1994 and 1995. 1 Although respondent at trial could not locate a copy of the 30-day letter mailed to Haas and his wife, and although petitioners did not produce a copy thereof, the limited evidence in the record on this point indicates that on Mar. 18, 1998, respondent mailed a 30-day letter to Haas and his wife that reflected the same adjustments that were reflected in the revenue agent’s report that had been mailed to Haas and his wife on Oct. 21, 1997.Page: 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