Wayne and Lois Hampton - Page 3




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          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 for                  








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