- 7 -
On July 17, 1998, respondent mailed to Haas and his wife and
to Haas & Associates the notices of deficiency reflecting the
individual and corporate adjustments set forth in the above
revenue agents’ reports and 30-day letters and reflecting the tax
deficiencies set forth above.
On September 15, 1998, the period of limitation was
scheduled to expire with respect to respondent’s authority under
section 6501(a) to assess a deficiency in Haas & Associates’ 1994
corporate Federal income tax liability.
On September 30, 1998, under an extension which Haas and his
wife had signed, the period of limitation was scheduled to expire
with respect to respondent’s authority under section 6501(a) to
assess a deficiency in Haas and his wife’s 1993 joint Federal
income tax liability.
On October 9, 1998, petitioners, through new counsel, timely
filed their separate Tax Court petitions –- Haas and his wife’s
petition with regard to the 1993 joint Federal income tax
deficiency determined by respondent and Haas & Associates’
petition with regard to the 1994 and 1995 corporate Federal
income tax deficiencies determined by respondent.
After respondent on November 24, 1998, filed his answers,
respondent’s administrative files were forwarded to respondent’s
San Francisco, California, Appeals Office for possible settlement
discussions and negotiations with petitioners’ counsel.
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