- 4 -
Deficiency for tax year 1995” for petitioner and Ms. Connor, but
that he would not be representing her. Mr. Jacob also sent a
copy of his letter to petitioner. Petitioner, however, has no
recollection of receiving the letter, and both petitioner and Mr.
Jacob deny discussing it. On her own, Ms. Connor petitioned this
Court seeking a redetermination of the 1995 deficiency
determination.
With respect to petitioner, Mr. Jacob did not file a
petition on his behalf or take any other action to advise him of
his available options with respect to the 1995 notice of
deficiency. Mr. Jacob attempted to convince the Court that it
was not his normal practice to file petitions without being asked
by the client, and the receipt of a copy of a notice of
deficiency regarding a client for whom he held a power of
attorney did not “obligate [him] to do anything”.
Thus, the 1995 tax liability was never challenged by
petitioner, and on February 4, 1999, respondent assessed the
amount of income tax due for 1995 against petitioner.
Respondent’s internal documents show several unsuccessful
attempts in 1999 and 2000 to try to reach Mr. Jacob regarding
collection actions. On June 27, 2001, respondent issued a Final
Notice of Intent to Levy (which petitioner did receive), advising
petitioner of the proposed collection of his outstanding 1995
income tax liability. On July 9, 2001, respondent received a
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011