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requested on the grounds that the "taxpayer is not ASAT, Ltd."
During the meeting on September 24, 1992, Ms. Hamilton advised
Ms. Maliwat of section 6038A, that respondent had the authority
to request documents concerning ASAT, Ltd., and that she needed
the documents to conduct the examination. The worldwide
organization chart, the Hong Kong income tax returns, audited
financial statements, and certain internal financial statements
of ASAT, Ltd., were provided to respondent on October 17, 1995,
after the statutory notice of deficiency was issued. No business
plans, market studies, feasibility studies, or corporate minutes
were provided to respondent. We cannot tell from the record
whether these items existed or were in the possession of
petitioner.
Ms. Hamilton notified petitioner's representatives,
including Mr. Borawski, during a meeting on June 14, 1993, that
she was considering an upward adjustment in petitioner's gross
profit spread to 14 percent by lowering its cost of goods sold.
Petitioner's Business as Described by Petitioner's
Representatives to Ms. Hamilton
During the examination, Ms. Hamilton was told by Mr.
Borawski and Ms. Maliwat that petitioner provided advertising for
the assembly services of ASAT, Ltd. During the initial interview
of the examination, Mr. Borawski advised Ms. Hamilton that
petitioner's business was contract representative services for
ASAT, Ltd.
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