- 5 -
petitioner’s 1989 and 1990 Federal income tax returns, and to
“address Sec 183 factors in writing and return.” Respondent’s
agent’s activity record reflects that on September 25, 1992, the
agent “reviewed data received.” By letter dated September 28,
1992, respondent’s agent forwarded to petitioner Form 5213,
Election to Postpone Determination as to Whether the Presumption
That an Activity Is Engaged in for Profit Applies, and requested
petitioner to complete and return it. By letter dated October
14, 1992, respondent’s agent reminded petitioner to submit Form
5213. On December 1, 1992, respondent received from petitioner
Form 5213, which reflected that petitioner signed it on October
16, 1992. As a result of respondent’s receipt of Form 5213,
respondent suspended the examination of petitioner’s returns.
During February of 1994, respondent’s agent Herrington
contacted petitioner with regard to the examination of
petitioner’s 1992 return. Later Agent Herrington expanded the
examination to include the years 1991 and 1993. On June 24,
1994, respondent mailed to petitioner a report disallowing
petitioner’s fishing activity losses for 1991, 1992, and 1993.
On July 19, 1994, Agent Herrington was informed that petitioner
had filed Form 5213. Therefore he suspended the examination of
petitioner’s returns and notified petitioner that the examination
was suspended.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: November 10, 2007