PREPARE A DEPOSIT LE'ITER Rick and Lori Doe have led joint returns for the last 10 years. The IRS has selected the Grimes' 2013 year for examination. Besides the return being filed late, one area of the IRS' inquiry is regarding certain Business expenses taken by Rick. Upon review of these business expenses, you determine certain expenses do not qualify as deductible business expenses and, because of the amount of the expenses deducted, there is a potential for the IRS to impose penalties. Rick has claimed these same business expenses in 2012 and in 2014. The Grimes also failed to disclose on their returns a foreign account they have had in the United Arab Emirates since 2010. You are handling the examination of the Grimes' 2015 tax year and have submitted your Power of Attorney to the IRS. Based on your review of the 2015 return and the Code, Regulations and other authorities, you have determined that certain business expenses of Rick may not qualify as necessary and ordinary business expenses. You have advised the Grimes of your determination and the potential that a deciency maybe asserted by the IRS on their 2015 tax year. However, as the IRS is now opening audits for the 2014 and 2016 tax years, it maybe several years before the examination of all three years is completed. The Grimes want to stop the running of interest on any potential liability for the 2015 tax year. Per your calculations, you estimate that the potential deficiency (tax, penalty and interest) would be $20,000. However, you believe that the Grimes have grounds for abatement of the penalty in that the Grimes reasonably relied on a written opinion from their prior accountant, Jenny Jones, who stated Rick could deduct these expenses as business expenses under IRC Section 162. Further, you believe that even if the expenses do not qualify as necessary and ordinary business expenses, you may argue the expenses are deductible under IRC Section 212. To stop the accrual of interest on any potential tax liability for their 2015 tax year, the Grimes want to make a deposit in the amount of the estimated tax, interest and penalty. However, the Grimes have stressed they may want to request the return of their deposit (with interest). Please draft a deposit letter meeting the requirements of IRC Section 6603 and Rev. Proc. 2005-18