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the deductions initially disallowed by the IRS in the
final examiner's report for the 1993 tax year.
The taxpayer understands that the time for filing
a Tax Court petition in this matter expires on or about
July 19, 1995, and that he will therefore be expected
to make a complete showing regarding the claimed
deductions at this meeting on June 27. Prior to the
meeting on June 27, an executed Form 2848 authorizing
Mr. Thiras to act on behalf of the taxpayer will be
prepared and delivered.
On behalf of the taxpayer, I want to thank you for
giving us this last opportunity to show the correctness
of the returns as filed without having to resort to
unnecessary and expensive litigation in the Tax Court.
If there is anything in particular that you believe
Mr. Thiras should bring with him to the upcoming
meeting (such as the type of supporting documentation
required), please let me know in advance of the meeting
date so that proper arrangements can be made. I am
mindful of the fact that given the late date of this
scheduled meeting, it will not be possible for the
taxpayer to seek a postponement. However, we would
appreciate being advised of the name of the examining
agent who will be assigned to this matter.
If you have any questions, please do not hesitate
to contact me.
Sincerely,
/s
STUART S. LIPTON
Petitioners did not present any documentation or explanations to
respondent at the time of this scheduled meeting.
Petitioners petitioned the Court on July 18, 1995, alleging
in their petition that they were not liable for any deficiency or
penalty for 1993. On September 18, 1995, the Court filed
respondent's answer to the petition. In her answer, respondent
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