- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011