- 3 - Subsequently, but before the filing of the petition herein, petitioner and Linda Evans were divorced. During 1981 through 1983, petitioner owned a corporation known as G.H. Evans & Company (Evans & Co.). In 1984, respondent commenced an examination of Evans & Co. for its taxable years 1981 through 1983 through a revenue agent named Robert M. Coar (Agent Coar). During the corporate examination, Agent Coar determined that petitioner had received interest-free use of corporate funds. Based on this determination, Agent Coar extended the examination to include petitioner's joint income tax returns for the taxable years 1981 through 1983. Petitioner's accountant, Eric Lear, represented petitioner during the examination. At the conclusion of the examination, Agent Coar made several income adjustments to petitioner's 1981 and 1982 taxable years. The adjustments for the 1982 taxable year were for unreported dividends from two sources (Evans & Co. and an unrelated payor) and additional wage income from an unrelated source. In a conversation with his supervisor, Agent Coar stated that these adjustments gave rise to the total tax liability attributable to petitioner's individual examination. Petitioner agreed to Agent Coar's adjustments and in March 1985 executed Form 4549, Income Tax Examination Changes. An Agent of respondent executed the form during the following month.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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