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4. A subsequent Branerton letter [informal
request for information] to petitioners sent
certified mail was returned with the hand-written
notation: "out of country for the next three
months--will be back August 5, 1997."
5. In August, the aforementioned letter was
resent, again certified mail, with three
suggested dates to meet and go over documents
and prepare a stipulation for trial. The letter
was not returned, but no one called or appeared
on any of the three dates.
6. On September 12, 1997, respondent mailed
a proposed Joint Stipulation of Facts to
petitioners by certified mail, including copies
of all the tax returns and the statutory notice
of deficiency. This mailing was received.
7. In a conference call with the Court on
October 7, 1997, petitioner Vernon W. Hartman
was ordered to meet with respondent and a Revenue
Agent, with his documents, on Friday, October 10,
1997.
8. Petitioner and respondent met for the
first time on that date, but Mr. Hartman did
not produce any documentation. He stated that
his diaries were being sent to Pennsylvania.
Mrs. Hartman did not appear for this conference.
* * * * * * *
20. * * * [R]espondent and the revenue agent
have offered and been scheduled to meet with
petitioner on nine separate occasions.
Petitioner has cancelled every one of these
dates, often with less than 24 hours' notice.
21. Petitioners still have not provided any of
the documentation for 1986, 1987, and 1988 needed
to verify the expenses deducted.
* * * * * * *
24. This Court has given petitioners more than
adequate time to complete this process.
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