- 3 - not all of the adjustments reflected in respondent’s above 30-day letter. Upon respondent’s review of the additional records provided, some adjustments set forth in the 30-day letter were conceded by respondent, and on August 27, 1998, respondent issued to petitioners a revised 30-day letter. On July 16, 1999, after petitioners had provided to respondent’s revenue agent yet additional records, respondent issued to petitioners a second revised 30-day letter, reflecting additional concessions by respondent. Petitioners again protested to respondent’s Appeals Office the adjustments set forth in respondent’s second revised 30-day letter. Petitioners then provided to respondent’s Appeals Office even more records relating to some of the remaining adjustments that had previously not been provided. Upon review of these records, respondent conceded or settled additional adjustments. On December 7, 2000, respondent mailed to petitioners a notice of deficiency for petitioners’ 1994 Federal income tax liability that reflected the adjustments that had not been agreed to, and on March 7, 2001, petitioners filed their petition herein. Shortly prior to the scheduled trial and as a result of additional records provided by petitioners to respondent for the first time, petitioners and respondent reached a basis forPage: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011