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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.
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