Tax Seminar #3 – December 3 2012

Internal Revenue Service
January 5, 2009
Page 2
4. Tax Periods Involved
Taxable year ended December 31, 2005
5. Adjustments with which the Taxpayer Do Not Agree
John Doe (the “Taxpayer”) disputes the adjustments identified in Form 4549-A, which would
increase the Taxpayers’ taxable income by $356,620 for December 31, 2005. The Taxpayer also
disputes the assessment of the Accuracy-IRS 662 penalty and that the proposed assessment of such
penalty is inconsistent with the Taxpayer’s previously agreed assessments.
In our analysis below, we are addressing the issues raised in Revenue Agent Jones’ 30-page
Explanation of Items, Form 886A, set forth as part of the report accompanying the adjustments to the
net income flowing through to the Taxpayer as the sole shareholder of ABC, Inc.
6. Statement of Facts, Law and Supporting Arguments.
A. Overview
[Insert Appropriate Language]
The undersigned hereby submits this protest along with the accompanying documents but does not know
personally that the facts contained herein are true and complete. However, I declare that the facts presented
herein are, to the best of my knowledge and belief, true, correct and complete.
A power of attorney (Form 2848) authorizing the undersigned to represent the Taxpayer in this matter
is enclosed.
Respectfully submitted,
EMD/saf
Encls.
cc: John Doe (via first class mail)
E. Martin Davidoff
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