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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 for
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Last modified: May 25, 2011