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was “defaulted”.6 See generally secs. 6225(a) and 6226(a)(1) and
(b)(1).
On September 24, 1996, Appeals Officer Koniarski prepared
“the FPAA default package” and forwarded it, along with the
administrative file, to the Associate Chief of Appeals for
approval. On October 11, 1996, the Brookhaven Service Center
received the FPAA default package for processing.
On February 3, 1997, the Brookhaven Service Center prepared
examination work papers relating to Mr. Leffert’s claimed
deductions from Blue Gem for 1982 and 1983. On February 27,
1997, Forms 4549-A, Income Tax Examination Changes, were issued
to petitioners for 1982 and 1983.
On March 9, 1997, Mr. Leffert sent a letter to the Problem
Resolution Office at the Brookhaven Service Center, objecting to
the Forms 4549-A he had received and the large amount of interest
that was to be assessed against petitioners. Mr. Leffert
complained that the IRS had inordinately delayed responding to
his protest letter. He maintained that, until receiving the
Forms 4549-A, he had received no other correspondence from the
IRS concerning the Blue Gem case for more than 8 years since
filing his appeal. Mr. Leffert claimed that the delay led him to
6Although the parties stipulated that the Blue Gem case was
defaulted, they did not define the term “defaulted”. We
understand the term to refer to the process of preparing to
assess a proposed tax deficiency after a taxpayer fails timely to
pursue available preassessment judicial remedies.
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