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office in Atlanta, Georgia (Atlanta office). As such, Ms.
Runyan’s duties included preparing and finalizing notices of
deficiency for so-called revenue agent or field cases (field
cases) in respondent’s Atlanta office. Pursuant to respondent’s
procedures that were in effect at all relevant times for such
cases, Ms. Runyan’s responsibilities included reviewing each such
case, preparing a notice of deficiency for issuance to the
taxpayer, having that notice proofread by an assistant, and
finalizing the notice of deficiency to be issued to the taxpayer
by making any necessary corrections or changes to that notice
resulting from that proofreading. (We shall refer to any notice
of deficiency that Ms. Runyan prepared and finalized pursuant to
the foregoing procedures of respondent as a final notice of
deficiency.)
Once Ms. Runyan finalized a notice of deficiency pursuant to
the foregoing procedures of respondent, three copies of the final
notice of deficiency were made, one of which was to be sent along
with the original of the final notice of deficiency to the
taxpayer, one of which was to remain in respondent’s administra-
tive file pertaining to that taxpayer, and one of which was to be
retained by respondent’s quality measurement staff. After the
three copies of the final notice of deficiency were made, the
original and those three copies of that notice were returned to
Ms. Runyan, who then signed the original and one copy of the
final notice of deficiency (signed original and signed copy,
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