- 4 - officer. The January 24, 1994, meeting was held, and the parties discussed petitioners' case. The Appeals officer described to petitioners the nature of respondent’s determinations. Petitioners explained their position in the matter and produced a small amount of evidence to support their arguments. The Appeals officer was not satisfied that petitioners had proven any error in respondent’s determinations but indicated that he would review the matter and send petitioners a list of evidence they needed to produce to overcome respondent’s determinations. Nothing else transpired until July 5, 1994, when another Appeals officer advised petitioners by letter that the case had been reassigned to him because of workload considerations, suggested a meeting at the Appeals Office at Ft. Lauderdale possibly to settle the case, and provided his assessment of petitioners' case. Petitioners responded that they could not meet on the suggested date and proposed a meeting at Ft. Myers, Florida, in September 1994. The Appeals officer responded that he was not going to Ft. Myers until late October and suggested petitioners come to his Ft. Lauderdale office in late September or October 1994 to attempt settlement. In the meantime, on August 5, 1994, the IRS office of District Counsel advised petitioners by letter that their case was calendared for trial at this Court’s trial session at Miami, Florida, commencing December 5, 1994, and it was necessary thatPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011