- 5 - 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 ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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