Bernard A. Kansky - Page 3

                                                - 3 -                                                   
                  In February 1996, after various meetings with respondent’s                            
            agents, petitioner submitted his delinquent returns for 1987                                
            through 1991.  Petitioner’s cover letter dated February 23, 1996,                           
            and addressed to respondent’s revenue agent, alluded to personal                            
            problems in petitioner’s family as the reason for the untimely                              
            filings and concluded:  “Again, thank you for your                                          
            professionalism and patience in the above matter during, and as a                           
            result of the difficulties we have faced”.                                                  
                  On March 19, 1996, respondent issued a 30-day letter,                                 
            proposing adjustments to petitioner’s taxes for 1987 through                                
            1991.  By letter dated March 20, 1996, petitioner protested the                             
            proposed adjustments.                                                                       
                  On September 16, 1998, after consideration of petitioner’s                            
            case by the Appeals Office, respondent issued to petitioner a                               
            notice of deficiency for 1987 through 1991.  On December 14,                                
            1998, petitioner filed a petition in this Court, seeking                                    
            redetermination of the proposed deficiencies and additions to                               
            tax.  On November 5, 1999, pursuant to the parties’ stipulation,                            
            this Court entered its decision in the deficiency case, deciding                            
            that petitioner had deficiencies of $2,413, $12,000, and $4,000,                            
            for 1987, 1990, and 1991, respectively, and had no deficiencies                             
            or overpayments for 1988 and 1989.  Petitioner did not appeal                               
            this decision.                                                                              







Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011