- 8 -
an unrelated, ongoing trial and, consequently, was not able to
meet with Appeals Officer Thurston until January 1993. Appeals
Officer Thurston asked Mr. Reising to submit a position paper at
the January meeting.
Mr. Reising did not submit a position paper at the January
meeting and was prepared to discuss only his belief that the
period of limitations on assessment for tax years 1983 and 1984
had expired. Appeals Officer Thurston replied by showing Mr.
Reising the Form 870-O with his signature. Because Mr. Reising
was not prepared to discuss the substantive R&D issue, Appeals
Officer Thurston asked him to submit the position paper by March
1993. On March 8, 1993, Mr. Reising called Appeals Officer
Thurston to inform her that he would have the position paper
completed that week. On March 19, 1993, during a telephone call,
Mr. Reising told Appeals Officer Thurston that he was still
working on the position paper. During May 1993, Appeals Officer
Thurston finally received Mr. Reising's position paper, dated
March 11, 1993.
Shortly after receiving the position paper, Appeals Officer
Thurston was sent to training for approximately 6 weeks. The TLP
case was not reassigned to another Appeals Officer while she was
in training. Appeals Officer Thurston was not able, because of
the training sessions, to respond to Mr. Reising's position paper
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011