- 3 - On or about February 21, 1995, petitioner filed an amended Federal income tax return for 1990, reporting additional taxable income of $134,859. Petitioner paid all of the additional tax due and accrued interest with respect to the foregoing amended returns. At some point between June 1994 and April 1995, petitioner’s 1993 taxable year was added to the examination covering 1992. In April 1995, petitioner’s examination was assigned to a new revenue agent, who discussed the examination of 1992 and 1993 on two occasions with petitioner’s representative. No additional information was obtained from petitioner by respondent after August 10, 1995. On or about August 25, 1995, the revenue agent examining petitioner’s returns initiated a civil fraud referral for 1992 and 1993, and on September 12, 1995, the agent issued a 30-day letter to petitioner proposing civil fraud penalties for those 2 years. On September 20, 1995, a special agent from respondent’s Criminal Investigation Division met with the revenue agent conducting petitioner’s 1992 and 1993 examination regarding petitioner’s case, and all civil action concerning those years ceased. On December 15, 1995, the special agent issued a memorandum to respondent’s Examination Division advising it to suspend or not initiate any civil action against petitioner forPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011