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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.
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