- 9 - discussed the subject of the home improvements. Specifically, the special agent was informed "the Richardsons were aware that Mr. Paige used corporate funds to improve their property, although they were not privy to the exact amounts or how those funds were disbursed". Also, Neilson attempted to categorize the unreported funds received by petitioner from the sale of PCCL equipment as either business or investment expenses. Sometime in the beginning of March 1997, respondent requested petitioners to extend the period of limitations with respect to the examination of the individual and corporate income tax returns. Petitioners did not agree to the extension. On February 28, 1997, respondent scheduled an appointment with petitioners for March 17, 1997, to conclude the examination of petitioners' return. On March 4, 1997, respondent contacted petitioners' attorney to cancel the March 17, 1997, appointment based on the belief the statute of limitations was set to expire. On March 5, 1997, respondent sent petitioners proposed changes to their 1993 tax return.4 On March 11, 1997, respondent issued a letter to petitioner notifying him that he was no longer the subject of a criminal investigation. On March 13, 1997, respondent issued the respective notices of deficiency. After petitions and answers were filed, petitioners met with respondent's appeals officer on several occasions. During these 4 We assume proposed changes were also sent with respect to PCCL; however, the record does not so indicate.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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