- 21 - On December 2, 1993, John’s father, who was petitioners’ then representative,6 sent petitioners’ verification information to Rowland. At some point, Rowland examined petitioners’ verification information and concluded that the amounts therein matched the amounts claimed on petitioners’ relevant tax returns. At some time between October 1 and October 15, 1994, Rowland determined whether petitioners were involved in a tax shelter other than TEA, and concluded that she did not need any further information from petitioners to compute their tax liability. At some time between October 15 and October 21, 1994, Rowland entered petitioners’ information into her computer. Rowland printed petitioners’ Form 5278 on October 21, 1994. On October 26, 1994, Rowland mailed the settlement documents (together with a Form 3610 (Audit Statement)) to petitioners. Petitioners signed the decision document on November 25, 1994, and mailed it to Rowland on December 14, 1994. Petitioners enclosed the following letter to Rowland with their signed decision document: 6 The parties have stipulated that John’s father was petitioners’ “representative” at the time of this letter. The parties also have stipulated that petitioners “proceeded pro se” in this Court after Shematz’s death, in 1989. We gather from this that John’s father represented petitioners before the Internal Revenue Service, but not before this Court.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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