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number of petitioners’ claimed expenses. Ms. Stephenson notified
Agent Sutton that the requested information would be provided by
the middle of November.
On November 15, 1996, Agent Sutton issued an IDR and
requested, among other items, substantiation of the income and
expenses with respect to petitioners’ 1993 through 1995 taxable
years, Beacon’s 1992 through 1995 taxable years, and “any other
entities which [petitioners] control or own” for the taxable
years 1992 through 1995. The IDR requested that this information
be provided by December 5, 1996.
In December 1996, Agent Sutton spent 2 days at Ms.
Stephenson’s office reviewing the documentation made available by
petitioners. On December 30, 1996, during respondent’s
examination, petitioners filed the 1993 return, 1994 return, and
1995 return.
On January 2, 1997, respondent notified petitioners by
letter that their individual returns for the taxable years 1993
through 1995 were also under examination, as well as Beacon’s tax
returns for the 1992 through 1995 taxable years and ISOA Inc.’s
tax returns for the 1994 and 1995 taxable years.
By letter dated January 17, 1997, petitioners requested that
the examination of the taxable years 1993 through 1995 be
transferred to respondent’s Dallas, Texas, office.
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