- 16 -
He advised me that if you do not sign a consent, the
90-day letter will be issued. The letter will not be
issued until the first part of January because of the
processing time necessary for us to do so. However,
Mr. Loendorf told me he agreed I would hold a
conference during the 90-day period in an attempt to
resolve the case.
I have not had the opportunity to review your case in
depth. However, it appears you received copies of the
examiner’s workpapers along with her audit report.
Therefore, at this time, you will not receive anything
further from me regarding “citations of law and/or
authority.”
I reserved a room in the Great Falls IRS office for
Thursday, January 18, 1996 in order to hold the
conference. * * *
By letter dated December 20, 1995, petitioners responded as
follows to Ms. Teichrow's letter of the previous day:
The tenor of your remarks indicates you intend no co-
operation. What is the point of scheduling a meeting
if the IRS intends to withhold the evidence necessary
to resolve the dispute?
* * * * * * *
We did receive copies “of the examiner’s
workpapers and her ... report,” as you suggest. * * *
The IRS has already been notified that none of us who
has reviewed the examiner’s work papers and report even
remotely understands what basis McConaughy could
possibly have used to make the determinations she did.
It is our right to know and understand that basis
before any meeting is scheduled. Because it is our
right to know and understand that basis - and also
because none of us can draft an intelligent reply to
the examiner’s allegations in our own defense because
we do not know and understand that basis - this
paragraph constitutes Notice to the IRS that until such
time as the support data we have repeatedly requested
are furnished, there will be no meeting. There is
nothing to meet about.
* * * * * * *
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