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application of section 6038A(e)(3) (hereinafter sometimes
referred to as the noncompliance penalty) for failure to provide
an authorization of agent. On January 3, 1994, respondent sent
petitioner a certified letter notifying petitioner that she had
applied the noncompliance penalty because petitioner had not
provided respondent with its appointment as agent for ASAT, Ltd.,
and that the noncompliance penalty would be reflected in a notice
of deficiency. Respondent also informed petitioner that she
would be applying the noncompliance penalty for failure to comply
with a summons that she issued to petitioner.
B. Information in Commissioner's Possession
At the initial interview of the examination on August 26,
1992, petitioner's representatives provided Ms. Hamilton with the
following documents:
a. Advertising brochures and folders;
b. Table of Contents;
c. Organization;
d. ASAT, Inc. Chart of Accounts;
e. Trial Balance 1991;
f. ASAT, Inc. General Ledger FY 1991;
g. Cash Receipts FY 1991;
h. ASAT, Inc. Cash Disbursements FY 1991;
i. ASAT, Inc. Sales Journal FY 1991;
j. ASAT, Inc. Freight Invoice Journal FY 1991;
k. Adjusting entries;
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