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petitioner a voice message stating that a statutory notice of
deficiency for 2000 and 2001 would be issued if petitioner failed
to contact respondent by April 1, 2004. The examining agent made
several more attempts to contact petitioner during the week of
April 5, 2004.
The Activity Record further indicates that on April 8, 2004,
petitioner informed the examining agent by phone that she
declined to extend the assessment period and that she wanted to
schedule a meeting on May 3, 2004. This is corroborated by
petitioner’s followup letter dated April 8, 2004, where she
stated that both she and her accountant would be available on May
3, 2004, and that the additional time would give her accountant
an opportunity to review her records as her accountant was not
the original preparer of the returns.
The examining agent agreed to a May 3, 2004, meeting. The
Activity Record indicates, however, that petitioner appeared
without her accountant on the date of the meeting. While
petitioner could have produced the books and records requested by
respondent at the May meeting, she did not do so. According to
the Activity Record, petitioner told the examining agent that she
needed 3 additional weeks to produce the books and records,
because her accountant was on vacation.
Respondent’s position in the statutory notice of deficiency
of June 29, 2004, premised the adjustments primarily on
petitioner’s lack of substantiation. Tax deductions are a matter
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Last modified: May 25, 2011