John Wadsworth - Page 3

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          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).                    




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