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On August 14, 1996, Agent Ruiz issued a 30-day letter to
petitioners in which she proposed changes to their 1993 return.
On August 27, 1996, petitioners sent a letter to respondent
agreeing and disagreeing, in part, with Agent Ruiz’s proposed
changes. Respondent interpreted petitioners’ letter as a request
that their case be transferred to the Appeals Office. On October
22, 1996, Appeals Officer Danny Raley (Appeals Officer Raley)
sent petitioners a letter requesting a conference to negotiate a
resolution of the matters with which petitioners disagreed. On
numerous occasions, Appeals Officer Raley requested documentation
supporting petitioners’ claimed NOL.4 Over the course of the
next year, respondent and petitioners resolved several issues
from the audit of petitioners’ 1993 return.
On October 7, 1997, Appeals Officer Raley informed
petitioners that he was returning their case to the examination
branch of the Internal Revenue Service to review petitioners’
documentation regarding the NOL. On October 23, 1997, Agent Ruiz
contacted petitioners to schedule a conference to discuss the
NOL. Petitioners informed Agent Ruiz that they did not wish to
meet with her and wanted their case assigned to a different
agent.
4Appeals Officer Raley sent letters to petitioners on Nov.
12, 1996, June 2, 1997, July 9, 1997, and Sept. 5, 1997,
describing the specific documents petitioners needed to produce
to substantiate their claim to the NOL.
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Last modified: May 25, 2011