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Notice of Deficiency 90-Day Letter


Department of the Treasury
Internal Revenue Service
Small Business and Self-Employed

24000 Avila Road, Mail Stop 5916
Laguna Niguel, CA 92677
Date: MAR 28 2014
Corporation’s Name
987 Channel Blvd., Ste. 620
Newport Beach, CA 92625

Form Number:
Employee Identification Number:
Person to Contact:
   IRS Employee Name
Telephone Number:
   (949) 389-4000
Last Day to File A Petition With
The United States Tax Court:

   JUN 27 2014


Tax Year Ended:                        December 31, 2011                     December 31, 2012
Increase in tax:                                 $691,107.00                              $340,683.00
Penalties or Additions to Tax
    IRC 6662(a)                                    138,221.40                                  68,136.60
Dear Corporation’s Name:
                                                          NOTICE OF DEFICIENCY

We have determined that you owe additional tax or other amounts, or both, for the tax year(s) identified above. This letter is your NOTICE OF DEFICIENCY, as required by law. The enclosed statement shows how we figured the deficiency.

If you want to contest this determination in court before making any payment, you have 90 days from the date of this letter (150 days if this letter is addressed to you outside the United States) to file a petition with the United States Tax Court for a redetermination of the deficiency. You can get a copy of the rules for filing a petition and a petition form you can use by writing to the address below.

United States Tax Court, 400 Second Street, NW, Washington, DC 20217

The Tax Court has a simplified procedure for small tax cases when the amount in dispute for each tax year is $50,000 or less. If you intend to file a petition for multiple years and the amount in dispute for any one or more of the tax years exceeds $50,000, this simplified procedure is not available to you. If you use this simplified procedure, you cannot appeal the Tax Court’s decision. You can get information pertaining to the simplified procedure for small cases from the Tax Court by writing to the court at the above address or from the court’s internet site at

Letter 531-T (11-2007)
Catalog Number 40222A

Send the completed petition form, a copy of this letter, and copies of all statements and/or schedules you received with this past letter to the Tax Court at the above address. The Court cannot consider your case if the petition is filed late. The petition is considered timely filed if the postmark date falls within the prescribed 90 or 150 day period and the envelope containing the petition is properly addressed with the correct postage.

The time you have to file a petition with the court is set by law and cannot be extended or suspended. Thus, contacting the Internal Revenue Service (IRS) for more information, or receiving other correspondence from the IRS won’t change the allowable period for filing a petition with the Tax Court.

As required by law, separate notices are sent to husbands and wives. If this letter is addressed to both husband and wife, and both want to petition the Tax Court, both must sign and file the petition or each must file a separate, signed petition. If more than one year is shown above, you may file one petition form showing all of the years you are contesting.

You may represent yourself before the Tax Court, or you may be represented by anyone admitted to practice before the Tax Court.

If you decide not to file a petition with the Tax Court, please sign the enclosed waiver form and return it to us at the IRS address at the top of the first page of this letter. This will permit us to assess the deficiency quickly and can help limit the accumulation of interest.

If you decide not to sign and return the waiver, and you do not file a petition with the Tax Court within the time limit, the law requires us to assess and bill you for the deficiency after 90 days from the date of this letter (or 150 days if this letter is addressed to you outside the United States).

NOTE: IF you are a C-corporation, section 6621(c) of the Internal Revenue Code requires that we charge an interest rate of two percent higher than the normal rate on corporate underpayments in excess of $100,000.

If you have questions about this letter, you may write to or call the contact person whose name, telephone number, and IRS address are shown on the front of letter. If you write, please include your telephone number, the best time for us to call you if we need more information, and a copy of this letter to help us identify your account. Keep the original letter for your records. If you prefer to call and the telephone number is outside your local calling area, there will be a long distance charge to you.

The contact person can access your tax information and help you get answers. You also have the right to contact the office of the Taxpayer Advocate. Taxpayer Advocate assistance is not a substitute for established IRS procedures such as the formal appeals process. The Taxpayer Advocate is not able to reverse legally correct tax determinations, nor extend the time fixed by law that you have to file a petition in the U.S. Tax Court. The Taxpayer Advocate can, however, see that a tax matter that may not have been resolved through normal channels gets prompt and proper handling. If you want Taxpayer Advocate assistance, please contact the Taxpayer Advocate for the IRS office that issued this notice of deficiency. See the enclosed Notice 1214, Helpful Contacts for Your “Notice of Deficiency”, for Taxpayer Advocate telephone numbers and addresses.

Thank you for your cooperation.


                                                                  John Koskinen
                                                                  By Susan G. Braunz
                                                                  Technical Services Territory Manager

Explanation of the tax changes
Notice 1214

Letter 531-T (11-2007)
Catalog Number 40222A