- 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. * * * * * * *Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011