- 11 - 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.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