Dartmouth Clubs, Inc. - Page 5




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          claimed in each of the years at issue for this expense was a                
          dividend paid to Lauzon, Jr.                                                
               On July 29, 1998, petitioner filed a petition with this                
          Court.  On September 28, 1998, respondent's answer was filed.               
               On September 25, 1998, respondent sent the case to Appeals             
          for consideration.  On June 10, 1999, an Appeals officer                    
          contacted petitioner's attorney, William F. Patten (Mr. Patten),            
          and the parties scheduled a conference for July 2.  The Appeals             
          officer requested that Mr. Patten bring copies of any Forms 1099            
          that petitioner had issued, a worksheet reconciling the Forms               
          1099 to the corporate records, and a list of all persons that               
          received less than $600 from petitioner.  Mr. Patten brought the            
          Forms 1099 to the conference, and he stated that the worksheet              
          and other information would be provided on July 7.  Preparation             
          of the worksheets took longer than expected, and petitioner was             
          not able to provide them by the promised date.                              
               On August 16, 1999, the Appeals officer received the                   
          worksheet and other requested information for both years in                 
          issue, except for any information about the $104,000 payments to            
          Lauzon, Jr.  After reviewing the worksheets and other                       
          information, the Appeals officer concluded that all the claimed             
          deductions were allowable as ordinary and necessary business                
          expenses, except for the $104,000 payments to Lauzon, Jr.                   
               Petitioner claimed, and respondent allowed, deductions of              






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