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reluctance, because he had already consented to one extension and
he believed the tax returns were “clean”. Ward and petitioners’
representative arranged an appointment for the afternoon of April
23, 1996, at petitioners’ representative’s office. This
telephone call was the first contact by IRS personnel with
petitioners or petitioners’ representative regarding petitioners’
tax returns since the time that the administrative files had been
transferred to Dallas. During the April 23, 1996, meeting,
petitioners’ representative and Ward conducted the initial
examination and reviewed petitioners’ tax returns. For 2 hours,
Ward asked petitioners’ representative numerous questions
relating to petitioners’ multiple business interests.
Petitioners’ representative’s responses to Ward’s questions were
as follows:
Schedule E: Curie Building, Galveston House
The Curie Building is an office building owned by Paulette.
It was purchased in 1987 and petitioners are personally liable on
the note obtained to finance the purchase.
Petitioners also owned a rental house in Galveston, Texas.
Paulette inherited the house and allowed her sister to live
there.
Petitioners’ S Corporations
Robert owned 100 percent of four S corporations, as follows:
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