Royce A. Ellis - Page 9

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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