- 16 - notice. The existence of a closing agreement covering specific matters for the years at issue does not abrogate respondent’s duty to issue petitioners a deficiency notice before assessment. Accordingly, we hold that respondent may not proceed with collection of petitioners’ liabilities. To reflect the foregoing, Decision will be entered for petitioners.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Last modified: May 25, 2011