Seymour and Beatrice Leffert - Page 11




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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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