1. If the taxpayer requests, or if the expiration of the statute of limitations is imminent, the Division Commissioner will skip the 30-day letter and issue a notice of deficiency to the taxpayer (i.e., a 90-day Letter)."); see also infra text accompanying note 99;J See;Administrative Audits: Audit Techniques and Procedure, ALI-ABA Course of Study Materials SR049,2010
2. Barr v. Harrah's Entertainment, Inc., No. 05-5056 (JEI), 2008 U.S. Dist. LEXIS 41632 (D.N.J. May 29, 2008)