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Section 7602(c) is effective for contacts made after the
180th day after the July 22, 1998, enactment of RRA 1998 (i.e.,
after January 18, 1999). See RRA 1998 sec. 3417(b), 112 Stat.
758.
Alleged Third-Party Contacts During the Examination
On brief, petitioners allege that during the initial
July 16, 1998, meeting, Leary told Carol that she had previously
contacted petitioners’ bank and that Leary subsequently asked
Carol why petitioners changed banks so often. Petitioners allege
that this line of inquiry “shows that she [Leary] had extensive
third party contacts”. Petitioners allege that they told Leary
that they wanted to be notified whenever a third party was
contacted, but they never received any third-party contact
information from the Internal Revenue Service (IRS).
Section 7602(c) has no application to any third-party
contacts that might have been made by respondent’s agents before
the January 19, 1999, effective date. The evidence does not show
that Leary or any other of respondent’s agents made any third-
party contacts after January 18, 1999, in the course of the
examination that culminated in the January 6, 2000, issuance of
the notice of deficiency.
Alleged Third-Party Contacts During Trial Preparation
On brief, petitioners allege that shortly before the October
2000 trial date, respondent’s agents contacted various third
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