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On September 2, 2005, petitioners telephoned the Internal
Revenue Service (IRS) to determine what additional information
was needed. The IRS representative indicated that petitioners
should provide Dr. Cowie’s name, address, and Social Security
number. Petitioners allege they sent the IRS a facsimile with
Dr. Cowie’s information on September 5, 2005.
The September 5, 2005, facsimile was not in the
administrative file when respondent answered the petition.
Respondent’s counsel received this facsimile from petitioners on
March 13, 2006. Respondent’s counsel forwarded this facsimile to
the Appeals Office.
On October 17, 2005, respondent issued a statutory notice of
deficiency to petitioners. The notice determined income tax due
and an addition to tax for taxable year 2003. Respondent based
the determination on information from third-party payors which
indicated that petitioners underreported interest, dividend, and
capital gain income of $2,180, $1,016, and $287,110, respectively.
The underreported income resulted in a determined deficiency of
$98,541, plus penalties and interest of $19,708.
On January 17, 2006, petitioners filed their petition. On
October 4, 2006, the parties filed a stipulation with the Court
disposing of all of the issues raised in the notice of deficiency.
On January 12, 2007, petitioners filed the instant motion.
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Last modified: November 10, 2007