- 4 -
petitioners dated October 11, 1995, notifying petitioners that
Appeals would soon arrange a conference. On January 16, 1996,
Appeals returned petitioners’ case to the IRS Examination
Division “for further development”. On February 21, 1996,
petitioners signed Form 872, Consent to Extend the Time to Assess
Tax, extending the period of limitations for 1992 to June 30,
1997.
On April 10, 1996, Appeals Officer John M. McNamee held
telephone conferences with petitioners, Ms. Ray, and Mr.
Ellsworth and scheduled an Appeals conference for May 3, 1996, in
Milwaukee, Wisconsin. Petitioners later canceled the Appeals
conference and apparently did not reschedule. In a letter dated
May 23, 1996, Appeals Officer McNamee offered petitioners a
settlement.
On May 31, 1996, petitioners again changed representatives,
replacing Mr. Ellsworth with David Grams, an attorney. Mr. Grams
notified Appeals Officer McNamee of the change via facsimile on
June 20, 1996. On or about June 27, 1996, and July 3, 1996, Mr.
Grams and Appeals Officer McNamee engaged in telephone
conferences but did not arrive at a settlement agreement.
Subsequently, on January 31, 1997, Mr. Grams signed Form 872-A,
Special Consent to Extend the Time to Assess Tax, extending the
period of limitations indefinitely for 1992, 1993, and 1994.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011