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ASAT, Ltd., had no sales people located in the United States
during its fiscal year ended April 30, 1991. Petitioner made
purchases on behalf of ASAT, Ltd. There were no written
agreements between petitioner and ASAT, Ltd., regarding the
purchases petitioner made on ASAT, Ltd.'s, behalf. Petitioner
paid for all advertising in the United States for itself and
ASAT, Ltd.
Internal Revenue Service (IRS) Audit of Petitioner
Respondent's examination of petitioner's tax year ending
April 30, 1991 (hereinafter the examination), began when a
notification of the examination was sent to petitioner on July
17, 1992. The examination continued until December 21, 1994, the
date the statutory notice of deficiency was issued. Nanette
Alexander Hamilton was the International Examiner who examined
petitioner's tax return for the tax year ended April 30, 1991.
During the examination, Ms. Hamilton met with petitioner's tax
counsel, Martin Schainbaum, and with Fe Maliwat, Robert Borawski,
and Conrad Chapple, all representatives of petitioner. Ms.
Maliwat was petitioner's controller from April 13, 1991, to
December 31, 1992. In addition to providing documents to Ms.
Hamilton, Ms. Maliwat responded to inquiries and explained
certain aspects of petitioner's business operations. Mr.
Borawski was petitioner's counsel and corporate secretary during
8(...continued)
outcome of this case.
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