-4- examination notice was an initial contact letter and did not offer petitioner an opportunity to meet with respondent’s Office of Appeals (Appeals). One day before mailing the examination notice to petitioner, respondent had checked his computer records for petitioner’s address. Those records listed petitioner’s address as 629 Mariola. Respondent did not mail an examination notice to petitioner at 629 Mariola. Petitioner timely filed (pursuant to extensions) a joint 2001 Federal income tax return (2001 return). Petitioner’s 2001 return was prepared by Campbell and reported that petitioner’s address was 4302 Callahan. Respondent received petitioner’s 2001 return on October 21, 2002, and processed it on November 18, 2002. On April 4, 2003, respondent checked his computer records for petitioner’s address. Those records listed petitioner’s address as 4302 Callahan. On the same day, respondent mailed a Letter 915(DO) (30-day letter) for 2000 to petitioner at 4302 Callahan. The 30-day letter informed petitioner that he could request a conference with the Appeals Office and was accompanied by two copies of the examination notice. On September 19, 2003, respondent mailed to petitioner at 4302 Callahan a Letter 1912(DO) that was accompanied by another copy of the examination notice. The Letter 1912(DO) stated that respondent’s Small Business and Self-Employed Division had reviewed petitioner’sPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011