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petitioner and requested copies of the bank records he used as the
basis of his findings. Mr. Guterman also requested additional time
to file a written protest to the findings. On November 7, 1995,
Revenue Agent Kropp advised Mr. Guterman that because petitioner
had not furnished the information she promised, petitioner's case
had been closed as unagreed and that the administrative file had
been sent to the notices section of the Laguna Niguel district of
the IRS. Mr. Guterman requested that the file be retrieved so that
petitioner could provide the necessary information; but on December
15, 1995, Revenue Agent Kropp informed Mr. Guterman that a notice
of deficiency was about to be issued and that petitioner's file
would not be returnable to him (i.e., to Revenue Agent Kropp).
FOIA Request
On December 15, 1995, Mr. Guterman filed a Freedom of
Information Act (FOIA) request with the IRS to determine the basis
of Revenue Agent Kropp's examination adjustments. On or about
April 16, 1996, Mr. Guterman received copies of petitioner's
examination files, including a partially redacted investigation
history, bank printouts, and bank deposit and withdrawal items for
the years in issue. The exam work papers for 1989 stated that "All
income is based on BDA [bank deposits analysis] done by Criminal
Investigation Division from LA District: Deposits being added to
income: $259,952." Similar work papers were prepared for 1987 and
1988.
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