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DONLEY v. C.I.R.

No. 85-4663.

791 F.2d 383 (1986)

Steven E. DONLEY, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

June 11, 1986.

Attorney(s) appearing for the Case

Martin A. Schainbaum, San Francisco, Cal., for petitioner-appellant.

Gary D. Gray, Atty., Glenn L. Archer, Jr., Asst. Atty. Gen., Dept. of Justice, Tax Div., Michael L. Paup, Appellate Sec., Richard Farber, Atty., Roger M. Olsen, Acting Asst. Atty. Gen., Fred T. Goldberg, Jr., Robert T. Ruwe, Washington, D.C., for respondent-appellee.

Before BROWN, REAVLEY and JONES, Circuit Judges.

PER CURIAM:

The Internal Revenue Service (IRS) sent petitioner Steven E. Donley a letter notifying him that it believed certain tax deductions were not allowable.1 The letter stated that the IRS was planning on reviewing his tax return in the future to determine if he claimed such deductions, and it gave him the opportunity to adjust his return before the review so as to avoid any penalties. The letter did not refer to any specific deficiency...

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