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By letter dated January 10, 1995, petitioner's attorney
provided to respondent additional information and statements from
petitioner.
On March 3, 1995, the Appeals Officer sent a letter to
petitioner conceding some adjustments, contesting others, and
requesting additional information about bank deposits. More
specifically, the letter stated, in pertinent part, that
respondent would concede $7,444 of the $7,449 adjustment for
payments from Hoffelt, et al., for the Sharer accountancy client
list, that respondent would concede the adjustment of $3,904
personal living expenses paid in cash, and that petitioner would
concede that the auto allowance of $3,000 from Gold Country was
includable in income. Furthermore, the Appeals Officer requested
additional information about $9,580 in checks written to
petitioner by Mary McDonald and $25,258 in funds deposited into
petitioner's investment account.
By letter dated March 19, 1995, petitioner's attorney
provided an affidavit from Mary McDonald with respect to the
$9,580 in checks written by her to petitioner and the $25,258
deposited into petitioner's investment account.
By letter dated March 22, 1995, the Appeals Officer conceded
all of the income items except the $3,000 auto allowance that
petitioner conceded was income. Respondent also conceded the
$150 Social Security adjustment. Petitioner conceded the
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