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During the period October 1994 through March 1995, Revenue
Agent Charles Caraway conducted an examination concerning
petitioner's tax liability for the taxable years 1991, 1992, and
1993. By letter dated October 12, 1994, Revenue Agent Caraway
invited petitioner to meet with him on October 24, 1994.
Petitioner did not appear for the meeting. After attempting to
contact petitioner by telephone, Revenue Agent Caraway received a
letter from Terry McMahon, purportedly acting as petitioner's
attorney-in-fact, requesting that Revenue Agent Caraway not
communicate with petitioner until after November 15, 1994. That
letter had the 2162 Ingleside address as the return address.
Revenue Agent Caraway made another attempt to arrange a meeting
with petitioner but apparently received no response. In March
1995, Revenue Agent Caraway prepared substitute returns computing
petitioner's tax liability for the years 1991, 1992, and 1993,
closed his file, and forwarded the matter to respondent's
District Director's office in Atlanta, Georgia.
During the period May through November 1995, Revenue Agent
Randie Bodner, then assigned to respondent's collection division
in Macon, Georgia, was responsible for collecting taxes from
petitioner and Terry McMahon for the years 1992 through 1995. On
June 29, 1995, Revenue Agent Bodner made a field visit to the
2162 Ingleside Avenue address and was advised by a receptionist
at that address that the McMahons had moved to a new address on
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Last modified: May 25, 2011