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Schwarmann), a revenue agent with 20 years of experience with the
IRS, acted as his mentor during the course of the audit,
providing guidance and assistance where and when needed.
Petitioner received an IRS audit notice in November 1988
from agent Gardner and turned the audit notice over to Mr. Raclaw
to contact the IRS directly. All communications subsequent to
the audit notice were exclusively between agents Gardner and
Schwarmann and Mr. Raclaw, acting on behalf of petitioners. The
initial appointment and many subsequent appointments were
canceled by Mr. Raclaw. Agent Gardner prepared a case activity
record indicating the activity on this case and the number of
canceled appointments.
Mr. Raclaw indicated that he would get the requested
information concerning petitioners' tax records to agent Gardner.
Mr. Raclaw never furnished the documents to agent Gardner, who
was forced to issue a summons to obtain the documents.
Agents Gardner and Schwarmann first met with Dr. Rao and Mr.
Raclaw on August 30, 1989. Agent Gardner examined income and
expense issues and also looked at bank statements. Petitioner,
when asked to produce bank account information, showed agent
Gardner information regarding two Midlantic Bank accounts, the
money market account and checking account. Agent Gardner became
aware that Dr. Rao received payments from sources other than
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