Robert Newstat - Page 5

                                        - 5 -                                         
          gross income, not taxable income; (2) the reason for this manner            
          of reporting was that records concerning his business expenses              
          were lost at the time he filed the return; and (3) he would file            
          an amended return when he recovered materials to support Schedule           
          C deductions.  Although petitioner never filed an amended 1999              
          return, the attachment to his Form 12153 expressed interest in              
          being allowed to make installment payments based on net, rather             
          than gross, income.                                                         
               Petitioner’s collection case for 1985 was assigned to                  
          Appeals Officer Joan R. Carter (Ms. Carter), of the Internal                
          Revenue Service (IRS) Office of Appeals in Newark, New Jersey.              
          Following her receipt of the case, Ms. Carter sent a letter dated           
          February 5, 2002, to Mr. Fendrick responding to the concerns                
          expressed in petitioner’s Form 12153.  The letter opened with the           
          following statement:  “Since my efforts to contact you by                   
          telephone have not been very successful the last few attempts,              
          this letter summarizes how the collection statute expiration date           
          was determined for each of periods listed above.”  With respect             
          to 1985, the letter then provided:                                          
               Assessment Date               11-17-1986                               
               Original Collection Statute Date11-17-1996                               
               Bankruptcy Petition TC 520    6-9-1986                                 
               Bankruptcy Lifted TC 521      9-22-1989 (Statute Suspended 3yrs.       
                                                       3mos. 14days)                  
               Original Collection Statute Date11-17-1996                               
               Plus: Suspension Period       3yrs. 3mos. 14days                       
               New Collection Statute Date   3-23-2000                                
               Collection Due Process Appeal 11-8-1999 (Statute Suspended While       
                                                       in Appeals)                    






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011