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petitioner asserts the notice of deficiency is invalid, and if
not, the burden of proof should shift to respondent.
If a taxpayer has a recognized representative, generally,
the Commissioner contacts the taxpayer through his or her
recognized representative. Sec. 601.506(a)(1), Statement of
Procedural Rules. An IRS employee conducting an examination may
request permission to bypass the taxpayer’s recognized
representative and contact the taxpayer directly if the
recognized representative unreasonably delays or hinders an
examination after repeated requests for nonprivileged information
necessary to the examination. Sec. 601.506(b), Statement of
Procedural Rules. If permission is granted, written notice of
such permission, briefly stating the reason why it was granted,
will be given to both the recognized representative and the
taxpayer. Sec. 601.506(b)(1), Statement of Procedural Rules.
Additionally, in a case where an IRS examiner and the
taxpayer fail to agree upon the examiner’s determination to
assert a deficiency or an additional tax, an IRS district
director will send to the taxpayer a “30-day letter”. Sec.
601.105(d)(1), Statement of Procedural Rules. The 30-day letter
is a form letter which states and explains the basis of the
examiner’s proposed determination and informs the taxpayer of his
or her appeal rights if the taxpayer disagrees with the proposed
determination. Id.
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Last modified: November 10, 2007