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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 and
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Last modified: May 25, 2011