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In the letter, respondent provided the following explanation:
Since the statute of limitations will expire for the
1999 year on April 15, we cannot issue a 30 day letter
that would allow you to file a protest to have your
case heard by our Appeals division. We send [sic] you
a statute extension earlier, but since you did not sign
and return the extension[,] April 15 remains the
statute date. If your case is unagreed, we will send
you a statutory notice of deficiency. This is a
certified letter than [sic] will allow you to file a
petition to have your case heard in Tax Court. * * *
Respondent also sent a copy of the Form 4549A and a brief cover
letter dated January 17, 2003, to petitioners’ attorney, Donald
L. Feurzeig.
In a notice of deficiency dated March 10, 2003 (the notice),
respondent determined the following deficiencies with respect to
petitioners’ income tax:
Year Deficiency
1999 $42,947
2000 73,891
2001 47,927
The notice contained the following errors: (1) An incomplete
explanation of Schedule E, Supplemental Income and Loss,
adjustments, (2) an alternative minimum tax computational error
twice disallowing petitioners’ 1999 net operating loss (NOL), and
(3) missing computations that would have explained the
adjustments to petitioners’ 1999 NOL.
On March 13, 2003, petitioners filed a petition with this
Court contesting respondent’s determinations. On April 24, 2003,
respondent filed an answer. Soon thereafter, in a letter dated
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Last modified: May 25, 2011