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Schedule A: Charitable Contributions
Petitioners had donated $343,000 worth of computer equipment
to El Paso in 1987. The equipment was in the Curie Building when
it was bought, in 1987.
Petitioners’ representative told Ward there was proper
documentation to verify all income and expense items shown on
petitioners’ 1991 and 1992 tax returns. Ward asked for
petitioners’ consent to extend for 1 year the time to assess the
income tax for 1991. Petitioners’ representative orally agreed
to a 6-month extension. Ward said she would prepare the Form 872
to cover the 6-month period and deliver the Form 872 to
petitioners’ representative’s office on April 25, 1996.
Petitioners’ representative told Ward to call before she came to
his office.
On April 22, 1996, Ward had prepared a Form 4564,
Information Document Request (hereinafter sometimes referred to
as an IDR) for petitioners’ 1991 and 1992 tax returns. An IDR is
an informal written request for information or documents from a
taxpayer. It serves as documentation that items have been
requested and provides to the taxpayer a list of items that the
taxpayer is to locate. It is not uncommon for an agent to ask
for information or documents orally and follow up with a written
request. Although this IDR had been prepared for the April 23,
1996, meeting, Ward did not leave it with petitioners’
representative, nor did Ward give to him any other writing
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Last modified: May 25, 2011