- 3 - On or about September 7, 1994, respondent sent a notice to petitioner at his Pittsburgh residence address that respondent would audit petitioner’s 1992 Federal income tax return. On September 9, 1994, petitioner telephoned respondent’s Pittsburgh, Pennsylvania, office to demand that the audit be postponed until May 1995 and transferred at that time to California, because petitioner’s business expense records were stored in California and it would be inconvenient and expensive for petitioner to retrieve them. Petitioner indicated that he intended to graduate from school and move back to California in May 1995. Respondent refused to delay the audit until May 1995. On October 25, 1994, respondent notified petitioner that petitioner’s 1993 Federal income tax return would also be audited. Between September and November 1994, petitioner had several further telephone conversations with respondent’s personnel. Petitioner demanded that respondent stop sending him “threatening” letters, indicated that he would not cooperate with the scheduled audits, and again indicated that he wanted to have the audits delayed to May 1995 and transferred to California. Because petitioner did not appear for an examination or submit documentary evidence to support his deductions, respondent on April 4, 1995, sent petitioner, at his Pittsburgh residence address, by certified mail, a notice of deficiency for 1992 andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011