Earl M. Hasbrouck and Donna M. Hasbrouck - Page 16

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               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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