Samuel T. Seawright and Carol A. Seawright v. Commissioner

117 T.C. No. 24

UNITED STATES TAX COURT SAMUEL T. SEAWRIGHT AND CAROL A. SEAWRIGHT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1796-00. Filed December 18, 2001. R’s examination of Ps’ tax liability commenced no later than July 16, 1998. After Ps petitioned this Court to redetermine the deficiency, R’s trial counsel informally contacted potential third-party witnesses without providing advance notice to Ps. 1. Held: Sec. 7602(c), I.R.C., which requires that R give the taxpayer advance notice of third-party contacts regarding R’s examination or collection activities,…