Taylor Miller - Page 9




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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