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petitioners an initial appointment letter, which proposed a
conference date of November 15, 1988. Petitioners failed to
contact respondent and did not appear at the scheduled
conference. On December 8, 1988, a second appointment letter was
sent to petitioners requesting that they call for a convenient
appointment.
Petitioners met with Office Auditor Barrow on December 22,
1988. At that time, petitioners provided information regarding
Mr. Lavallee's employment at Paul Arpin and his compensation and
expenses in connection therewith. On December 23, 1988,
respondent sent a Letter 1995(DO) to Paul Arpin, requesting
employment-related information with respect to Mr. Lavallee.
Office Auditor Barrow also sent petitioners three Information
Document Requests (Form 4564), which were dated December 22,
1988, December 23, 1988, and January 9, 1989. The documents
provided on December 22, 1988, were the only documents that
petitioners provided to respondent prior to respondent's issuance
of the notice of deficiency.
On January 17, 1989, Office Auditor Barrow was assigned
petitioners' 1987 Federal income tax return, which had also been
selected for audit.3
3Office Auditor Barrow had requested information with
respect to petitioners' 1987 year in the initial appointment
letter she sent petitioners on Oct. 20, 1988, and in the Forms
4564 that she issued to petitioners on Dec. 23, 1988, and Jan. 9,
1989.
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