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September 22, 1992, petitioners filed a written protest and
request for Appeals to review the case. On December 3, 1992,
Appeals received the materials related to petitioners’ case. In
February or March of 1993, because Examiner Kruse had not
prepared a Revenue Agent Report (RAR), the case was sent back to
respondent’s examination division.
Second Examination
Revenue Agent Jimmy Bose was assigned to petitioners’ case.
Beginning in April 1993, Agent Bose issued IDR's to petitioners
and prepared draft RAR's. On October 8, 1993, Agent Bose
prepared a complete RAR with explanations for the 1988 tax year.
Petitioners and Agent Bose continued working toward a resolution
of the case. On December 16, 1993, Agent Bose issued another IDR
and, on July 8, 1994, issued a summons to petitioners. On August
17, 1994, Agent Bose prepared a RAR with regard to the 1985 tax
year, disallowing the net operating loss carryback from 1988 and
denying the claimed refund for 1985.
On October 19, 1994, respondent issued a notice of
deficiency to petitioners for their 1988 tax year. On
December 16, 1994, petitioners filed a petition with this Court
seeking a redetermination of the deficiency for 1988 as
determined by respondent. On January 23, 1995, respondent issued
an official notice of disallowance of the claimed refund for
1985. On March 21, 1996, the Court entered a stipulated decision
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