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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 some
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Last modified: May 25, 2011