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not want to extend the period of limitations. However, later
in July, Mr. Schultz agreed to extend the period of limitations
to March 31, 2003, and AO Caruso prepared a new Form 872.
On August 2, 2002, AO Caruso received the Form 872 signed by
petitioner, extending the period of limitations to March 31,
2003, for assessment of petitioner’s 1998 income taxes.
From September 9 through 13, 2002, AO Caruso attended
mediation training. On September 16, 2002, the parties agreed to
hold an Appeals conference on November 7, 2002. On October 7,
2002, Appeals Officer Nelson Leduc (AO Leduc) replaced AO Caruso.
Mr. Schultz and respondent each left a voicemail for the other in
October. On October 31, 2002, AO Leduc prepared a form to extend
the period of limitations for assessment until December 31, 2003.
However, at the Appeals conference held on November 7, 2002,
Mr. Schultz declined to extend the period of limitations for
assessment and instead requested 2 weeks to review relevant tax
law. Between November 25 and December 5, 2002, Mr. Schultz and
AO Leduc discussed extending the period of limitations.
Respondent received from petitioner a signed extension of the
period of limitations on assessment on December 5, 2002,
extending the limitations period to December 31, 2003, for 1998
and 1999.
AO Leduc was on annual leave from December 14, 2002, to
January 13, 2003. On January 13 and 14, 2003, AO Leduc contacted
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