Steven E. Donley v. Commissioner of Internal Revenue

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 in Donley’s tax return or suggest in any way that the IRS had already determined that Donley had miscalculated the tax due. Donley, along with other taxpayers,…