- 5 - On December 29, 1997, respondent issued a notice of deficiency to petitioner determining fraud penalties under section 6663 for 1992 and 1993. Petitioner filed a timely petition in this Court, seeking a redetermination of the fraud penalties for 1992 and 1993. On July 6, 1998, petitioner’s conviction was affirmed by the Court of Appeals for the Sixth Circuit. On or about August 3, 1998, petitioner received a letter from respondent stating in part: “Thank you for your inquiry of June 05, 1998. We have resolved your problem with your 1989 tax return. Please disregard the prior request.” By memorandum dated March 3, 1999, District Counsel of respondent advised respondent’s Examination Division that the criminal proceedings against petitioner were concluded. In connection with the proceedings in this Court concerning a redetermination of the 1992 and 1993 fraud penalties, petitioner and respondent became involved in a dispute over discovery and a continuance of the trial. On July 16, 1999, petitioner requested a continuance, which was granted on July 20, 1999. On July 19, 1999, the revenue agent who conducted the examination of petitioner’s 1992 and 1993 taxable years met with respondent’s counsel at the U.S. attorney’s office to review the record in petitioner’s criminal case. At that time, upon a review of the criminal case record and the administrative file,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011