John D. Spivey and Pamela K. Spivey - Page 3




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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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