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Because petitioners failed to submit the requested documentation
substantiating the disputed deductions, respondent determined a
deficiency of $2,877 and sent petitioners a notice of deficiency
on June 6, 2005.
Respondent advised petitioners by letter dated June 22,
2005, that their case would be transferred to respondent’s
Appeals Office, and on June 27, 2005, respondent transferred the
case to the Appeals Office. Mr. Mann sent a letter to respondent
on August 4, 2005, requesting that respondent rescind the notice
of deficiency. That letter was not accompanied by documentation
to support petitioners’ claimed deductions.
Petitioners timely filed their petition in this Court on
September 6, 2005. Respondent filed his answer on October 25,
2005. By notice dated November 10, 2005, the instant case was
placed on the April 3, 2006, calendar in Philadelphia,
Pennsylvania.
On March 27, 2006, Ms. Tyrrell sent documentation to support
the deductions in question to Mr. Mann. Ms. Tyrrell faxed the
documentation to respondent’s counsel the same day. On April 3,
2006, the parties filed a stipulation of settled issues at the
call of the instant case from the Philadelphia trial session
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Last modified: May 25, 2011