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Financial's 1987 taxable year. Appeals made this request due to
the disallowed loss carryforward from 1987 to 1988.
Settlement negotiations between the parties continued
through September 11, 1995, when it became apparent to the
parties that they would be unable to reach a mutually agreeable
settlement. Petitioners' counsel sent the Appeals officer a
letter requesting the case be transferred back to District
Counsel, citing his objection to the Appeals officer's continued
demands for additional documentation. On September 15, 1995,
Appeals referred the cases back to District Counsel for trial
preparation.
Shortly thereafter, District Counsel was notified by the
examination division that Simpson Financial's 1987 Federal income
tax return would not be audited. Petitioners and District
Counsel held a conference on December 14, 1995, to discuss the
cases in preparation for trial. At that conference, the parties
reviewed various documentation that petitioners provided in
response to District Counsel's informal discovery request. While
some of this documentation had been provided earlier by
petitioners to respondent either at the audit level or later at
the Appeals level, petitioners furnished additional documentation
that had not previously been provided to respondent. The parties
settled all issues raised by the notice of deficiency issued to
Simpson Financial, including the NOL carryforward, which
respondent conceded. Respondent conceded the NOL issue after the
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