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The letter stated further that petitioner and his wife
anticipated each of the delinquent returns would show an income
tax refund of several thousand dollars and emphasized that
petitioner and his wife did not owe any additional taxes for the
years 1993, 1994, and 1995. The letter stated petitioner and his
wife were due refunds for each year. The letter referenced
petitioner’s Social Security number and was sent on behalf of
both petitioner and his wife. Only petitioner’s wife signed the
letter, however.
On December 29, 1997, respondent mailed notices of
deficiency for 1993 and 1994 to petitioner. The notices of
deficiency did not refer to the April 1996 letter. Petitioner
filed a timely petition in response to the notices.
On March 30, 1998, petitioner and his wife filed joint
Federal income tax returns for 1993 and 1994 with the Internal
Revenue Service Center at Kansas City, Missouri. The 1993 and
1994 returns reported the following:
Income tax
Year withholding Income tax due Overpayment
1993 $13,834 $10,414 $3,420
1994 13,658 7,737 5,921
3(...continued)
1996 letter was introduced as an exhibit in this case by either
party. Our findings of fact regarding the contents of the April
1996 letter are drawn from the testimony of petitioner and his
wife, which we concluded was credible. Respondent did not
contest their description of the April 1996 letter.
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