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19, 1996, Ms. Erickson attended Phase III Audit training. Ms.
Erickson’s group manager, Pat Lewis, instructed Erickson to
retain petitioners’ audit case until completing the aforesaid
training.
Petitioners’ case was assigned to Ms. Erickson during the
entire period of her training. Ms. Erickson had neither the
authority to determine whether and when to go to training classes
nor the authority to transfer petitioners’ case to a different
agent. On April 2, 1996, Ms. Erickson mailed to petitioners a
copy of their Individual Income Tax Examination Changes (audit
report).
In June 1996, the audit of petitioners’ 1993 return was
transferred to Revenue Agent Carol A. Ruiz (Agent Ruiz).
Petitioners’ case was transferred because Ms. Erickson moved. On
July 1, 1996, Agent Ruiz issued Form 4564, Information Document
Request (IDR), which asked for petitioners’ workpapers
supporting, inter alia, their claim to a net operating loss
carryover on their 1993 return (the NOL). On July 9, 1996, Agent
Ruiz, by letter, explained to petitioners the need for
documentation supporting their claim to the NOL. On July 18,
1996, Agent Ruiz issued a second IDR which requested supporting
documents. Petitioners failed to provide Agent Ruiz with the
requested documentation.
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