- 9 - We are required by law to notify taxpayers in writing if we need to reexamine their books and records after previously examining them. Because information that may affect your tax liability has been developed since we last examined your books and records, please make them available to us for reexamination. Thank you for your cooperation. On October 14, 1997, petitioner signed another Consent to Extend the Time to Assess Tax (Form 872), which extended the period of limitations for assessment for the 1992 tax year until December 31, 1998. On April 9, 1998, respondent issued the notice of deficiency for the 1992 tax year to petitioner. When respondent issued the notice, the period of limitations for assessment for the 1992 tax year had not expired. Petitioner claims she relied on respondent’s April 25, 1994, no change letter for “a sense of security,” but she did nothing in detrimental reliance thereon. For some years, petitioner has been her mother’s primary source of support; petitioner’s income tax returns for the years 1989 through 1996 claim her mother as a dependent. Commencing early in the calendar year 1998, petitioner became the primary source of support for one of her nephews. To provide the context for respondent’s change of the position evidenced by the no change letter, we make somePage: 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