- 7 - was taking place. Prior to July 1993, in response to a document request dated February 8, 1993, Guerra sent Revenue Agent Allen Sohrt (Agent Sohrt) a copy of the Note, which was unsigned. On July 16, 1993, Guerra met with Agent Sohrt, at which time Agent Sohrt requested a signed copy of the Note as well as copies of any checks showing payments on the Note. Guerra looked for the documents requested at the July 16 meeting and did not find any copies of checks, so he notified Eagleson. On July 22, 1993, petitioner made his first payment on the Note, equal to two principal payments of $15,400 each and interest accrued to date of $36,961.68. On August 2, 1993, Guerra sent Agent Sohrt a signed copy of the Note and stated in a cover letter that petitioner had missed the first payment due on the Note (the July 2, 1992, payment), in part because of the failure of the accountants at Davidson, Eagleson to notify him the payment was due. At the time he sent this letter, Guerra had not been made aware that the Note had been signed in 1992, and the letter made no mention of when the Note had been signed. On October 8, 1993, Agent Sohrt wrote Guerra asking petitioner to provide a signed statement as to when the Note had been signed. Later that month Guerra drafted a letter for Eagleson's signature stating that the Note had been signed on or shortly after May 26, 1992, even though it was effective July 2, 1990. This letter advised that the accountants were partly responsible for the failure to prepare the Note at the time of the transfer of the Ranch.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011