- 3 - informed that his 1989 through 1992 tax years were under examination and respondent scheduled a conference with petitioner for April 16, 1994. Petitioner did not attend the April 16, 1994, proposed conference. By letter dated April 18, 1994, John B. Kotmair, Jr., petitioner's then representative,2 informed respondent's auditing agent that petitioner had given him a power of attorney to represent him. Mr. Kotmair then set forth the conditions under which he and petitioner would meet with the auditing agent. Those conditions were, inter alia, that the auditing agent was to provide Mr. Kotmair: 1. A copy of the guidelines for the meeting; 2. All the specific information and/or documents that are sought; 3. The home address, telephone number, proper name, job title and employee number of John F. Murphy; the District Director; Group Manager; and any other Internal Revenue Service employees connected with this instant action. The authority for this inquiry is found within: U.S. v. Roundtree, 420 F.2d 845; and, 4. Copy of the notification or order, made pursuant to Delegation Order 24 requiring Mr. Wadsworth to keep books and records for submission, upon demand, to the Internal Revenue Service; 5. Copy of the District Office Delegation Order authorizing Mr. Wadsworth's records to be summoned and testimony to be required; 6. The bond number of all agents who will have access to the information they are demanding. 2 John B. Kotmair was convicted of willfully failing to file income tax returns for 1975 and 1976 in violation of section 7203. See Kotmair v. Commissioner, 86 T.C. 1253 (1986).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011