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prepared in connection with the case in chief are protected from
discovery under the work product doctrine privilege in connection
with these motions.
Background
When the petition was filed in the instant case, petitioners
resided in Glendale, Arizona.
Petitioners timely filed their 1993 Federal income tax
return. Petitioners showed a $9,238 tax liability for 1993. On
January 9, 1996, respondent sent to petitioners a notice of
deficiency that determined a $20,710 deficiency (liability of
$29,948, minus the $9,238 liability shown on petitioners’ tax
return) and a $4,142 penalty under section 6662(a). On March 29,
1996, petitioners sent a petition to the Court (docket No. 5931-
96, hereinafter sometimes referred to as the 1996 case) disputing
the entire amounts of the deficiency and penalty so determined.
Also on March 29, 1996, petitioners sent to respondent a
second amended 1993 tax return (Form 1040X, Amended U.S.
Individual Income Tax Return) showing a tax liability of $21,893,
and showing that this was $12,655 greater than the liability they
had previously reported. On May 27, 1996, respondent made an
additional assessment of the $12,655 shown on this Form 1040X,
along with interest, and notified petitioners of this additional
assessment.
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