Donald C. Richardson and Rita M. Allaire - Page 9

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          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.                          

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