Estate of Eileen K. Brocato - Page 5




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          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:                                                    











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