- 8 - At trial, petitioners submitted a letter addressed to them from respondent that states: “Your Federal income tax return for the year shown below has been selected for examination.” The tax year indicated is 1995. The letter is signed by Revenue Agent Dwight Krstulja. The typewritten date on the letter of “09-15- 98” is crossed out and “11-03-98” is handwritten in. The typewritten appointment date on the letter of “Friday, October 23, 1998” is crossed out and “Tuesday December 8, 1998” is handwritten in. The letter continues: “This is a field examination and will be conducted at your place of business or other convenient location.” Attached to this letter is an information document request (IDR). The IDR bears a typewritten date of “09-15-98” and a handwritten date of “11-3-98”. The IDR also references the October 23, 1998, scheduled appointment. Respondent contends the audit began before July 22, 1998. The Court kept the record open for 30 days after the trial for respondent to submit evidence as to when the audit of petitioners’ returns began. Respondent submitted a memorandum from “MACS Coordinator” to “Examiner” in the Southern California District and a tax module for petitioners. The top of the tax module bears the following notation: “Thu, 18 Dec 1997, 8:24 am.” Neither the tax module nor respondent explains what thisPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011