- 8 - files contained no canceled checks, bank statements, or bank deposit slips. A "Branerton letter", dated November 26, 1996, from District Counsel Udrys was sent to Mr. Guterman informing him that respondent was preparing for trial. The letter specifically requested any documentation in Mr. Guterman's possession that would demonstrate the nontaxable sources of petitioner's bank deposits. Mr. Guterman requested (and received) additional time to prepare answers to the Branerton letter questions and complete his own bank deposits analysis. By letter dated February 24, 1997, District Counsel Edwin Herrera again asked for Mr. Guterman's responses and bank deposit analysis. On March 13, 1997, Mr. Guterman forwarded his Branerton letter responses and bank deposit analysis to district counsel's office. On April 30, 1997, following several telephone conferences between respondent and Mr. Guterman, Appeals Officer Millang formally offered a settlement proposal which subsequently led to the stipulation of settled issues. Petitioner then sought reasonable litigation and administrative costs from respondent, which respondent rejected. On June 20, 1997, petitioner filed the instant motion for award of litigation and administrative costs. DiscussionPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011