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files contained no canceled checks, bank statements, or bank
deposit slips.
A "Branerton letter", dated November 26, 1996, from District
Counsel Udrys was sent to Mr. Guterman informing him that
respondent was preparing for trial. The letter specifically
requested any documentation in Mr. Guterman's possession that would
demonstrate the nontaxable sources of petitioner's bank deposits.
Mr. Guterman requested (and received) additional time to prepare
answers to the Branerton letter questions and complete his own bank
deposits analysis. By letter dated February 24, 1997, District
Counsel Edwin Herrera again asked for Mr. Guterman's responses and
bank deposit analysis. On March 13, 1997, Mr. Guterman forwarded
his Branerton letter responses and bank deposit analysis to
district counsel's office.
On April 30, 1997, following several telephone conferences
between respondent and Mr. Guterman, Appeals Officer Millang
formally offered a settlement proposal which subsequently led to
the stipulation of settled issues.
Petitioner then sought reasonable litigation and
administrative costs from respondent, which respondent rejected.
On June 20, 1997, petitioner filed the instant motion for award of
litigation and administrative costs.
Discussion
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