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Thus, the Internal Revenue Service is generally limited to
one inspection of a taxpayer’s books and records for each taxable
year unless the taxpayer requests a second audit or the Service
notifies the taxpayer in writing that an additional inspection is
necessary. United States v. Powell, supra; De Masters v. Arend,
313 F.2d 79, 85 (9th Cir. 1963).
However, the review of records of third parties does not
constitute an inspection of the taxpayer’s books and records.
Digby v. Commissioner, supra at 447. Moreover, mere
communication with the taxpayer does not fall within the scope of
an inspection of books and records. Benjamin v. Commissioner, 66
T.C. 1084, 1098-1099 (1976), affd. 592 F.2d 1259 (5th Cir. 1979).
With this background we consider petitioner’s contention
that respondent has violated the requirements of section 7605(b)
by subjecting petitioner to three separate inspections of her
books and records.
Petitioner attached to her Form 1040 for taxable year 1999,
a “Special Handling” cover letter requesting a review of her
return. Petitioner presented no evidence that respondent audited
her return as a result of this request. In fact, respondent
mailed petitioner a letter thanking her for her inquiry and
stating that the IRS had not “resolved the matter.” Such a
response to a taxpayer’s inquiry does not constitute an
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