- 5 - David P. Rhoades & Associates, Inc. (Rhoades report). In the spring of 1995, Marc Samuelson (Mr. Samuelson), an estate tax attorney for the Internal Revenue Service (IRS), began an audit of the return. On June 26, 1995, an IRS engineer issued a review report concluding that the values before discounts determined in the Rhoades report were acceptable, but the amounts of the discounts claimed were unacceptable. Mr. Samuelson made a settlement proposal to petitioner, but petitioner rejected it. On October 10, 1995, Mr. Samuelson told petitioner’s counsel that respondent would not be relying on the IRS engineer’s report and respondent would be hiring an appraiser to value the properties. He informed petitioner’s counsel that this process would take at least 3 months, and he would contact counsel when the expert was hired. On November 14, 1995, petitioner filed a supplemental estate tax return (the supplemental return) with respondent’s Ogden Service Center claiming an interest deduction. On December 14, 1995, the Ogden Service Center erroneously issued petitioner a closing letter in response to the supplemental return. The closing letter provided:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011