- 3 -
(hearing notice) to Mr. Muldavin for 1987 and a hearing notice to
petitioners for 1988, 1989, and 1991.
On August 27, 1999, the register’s office recorded the FTL
notices.
On or about September 6, 1999, petitioners filed a Request
for a Collection Due Process Hearing, Form 12153. Petitioners
explained their disagreement with the FTL notices as follows:
We are currently before the U.S. Tax Court for 1985-89
with the opportunity to open 1980 for greater oil
depletion allowances. Adjustments for carryforward and
carryback credits have not been made for depletion,
depreciation, and prepayments (as the court so ordered)
nor has the Commissioner fullfilled [sic] its promises
to make such adjustments in exchange for our not going
to trial over proper business expenses in Ann Arbor,
Michigan.
Pursuant to petitioners’ request for a hearing, Appeals
Officer Mary Jo Fedewa held a hearing attended by petitioners and
Ms. Fedewa. Petitioners raised two issues at the hearing: (1)
They challenged the underlying deficiencies,3 and (2) they
claimed that respondent had not followed proper procedures in
providing them with the hearing notices.
Ms. Fedewa verified that for each of the years in issue
petitioners received a statutory notice of deficiency, they
petitioned the Court, and a decision had been entered. Ms.
Fedewa also verified that on August 2, 1999, respondent prepared
3 Petitioners claimed they were entitled to additional
depletion allowances and wanted respondent to change the
computation of their underlying liabilities.
Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011