- 6 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011