- 8 - petitioners’ motion on the basis of the limitation imposed by section 7430(b)(1). We need not, and do not, reach the other issues raised by respondent. Respondent’s response to petitioners’ motion points out that a 30-day letter was issued to petitioners. See sec. 601.105(d), Statement of Procedural Rules. A copy of that 30-day letter is attached as an exhibit to respondent’s response. The letter pointed out that if petitioners did not agree with the proposed changes in their 1994 and 1995 returns, then they could obtain a conference with the Regional Office of Appeals. The 30-day letter also explained the steps necessary to obtain such an Appeals conference. Respondent’s brief further represents that after issuing the 30-day letter, respondent’s agent contacted petitioners’ representative. According to respondent’s response, petitioners’ representative advised the agent that petitioners did not agree to the adjustment, but they would not file a protest. Petitioners’ representative recommended that the agent issue a notice of deficiency. The 30-day letter issued to petitioners proposes increasing their net earnings from self-employment for 1994 and 1995 by the amount of the real estate rental paymentsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011