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public accountant, forensic accountant, and certified fraud
examiner. She is not, however, a certified public accountant,
nor is she licensed by the State of Colorado to practice
accounting. She has never been employed by the IRS, and is not
an enrolled agent or otherwise authorized to represent taxpayers
before the IRS pursuant to Treasury Department Circular No. 230,
Practice Before the Internal Revenue Service, 31 C.F.R. Part 10
(Rev. 6-2005). Among other things, she testified to the
following: She had told Mr. Jones that the assessments of tax in
these cases with respect to the taxable years in issue of both
Mr. and Ms. Davis were time barred. The date of assessment of
tax is the date an officer of the IRS signs a summary record of
assessment. The data necessary to compile a summary record of
assessment, however, is only available for that purpose after it
has been posted to the IRS’s master file system. On the basis of
her examinations of transcripts of petitioners’ individual master
files for the years at issue, which revealed postings of
assessments on dates subsequent to the assessment dates shown on
those transcripts, she had reached the conclusion that the
assessment dates were not accurate and the true assessment dates
were the dates of the postings.
Both Mr. Jones and Ms. Lacorte were accorded the opportunity
to be heard with respect to our orders to show cause why excess
costs should not be imposed on them pursuant to section
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Last modified: November 10, 2007