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Background
At the time the petition in this case was filed, petitioner
resided in Warwick, Rhode Island.
For the years in issue, petitioner was self-employed and
operated a business called K.S. Gabrielle Interiors which
provided the selection and installation of custom-made draperies,
bedspreads, blinds, and floor coverings. As part of her
business, petitioner maintained sample books for fabrics, blinds,
and shades, as well as sample carpeting for display to customers.
Petitioner’s daily routine included several visits to customers’
homes to provide, among other things, advice for selecting proper
styles and colors, measurements, and price estimates.
On November 18, 2003, respondent sent to petitioner an
initial appointment letter, requesting her to meet with an
examining agent on January 8, 2004. At the same time, respondent
issued to petitioner a Form 4564, Information Document Request
(IDR), which was directed at obtaining books and records that
would substantiate petitioner’s cost of goods sold and business
expenses claimed on her returns.
On March 5, 2004, respondent forwarded to petitioner Form
872, Consent to Extend the Time to Assess Tax, and Publication
1035, Extending the Tax Assessment Period, requesting that
petitioner agree to extend the period of limitations for
respondent to assess the 2000 and 2001 taxes. In the absence of
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Last modified: May 25, 2011