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deficiency. On July 23, 1996, petitioner delivered three boxes
of documents regarding his 1993 and 1994 tax years to
respondent’s auditors. At this time, petitioner was informed by
Barbara Gee (Gee), respondent’s auditor, that her office no
longer had petitioner’s administrative files and that she could
not review petitioner’s documents without the administrative
files. Consequently, Gee requested that petitioner contact ESP
to request that his administrative files be sent back to Gee’s
office. Gee also requested that petitioner make an appointment
to review his documents with respondent’s auditors. Petitioner
was unwilling to make an appointment.
On August 16, 1996, respondent sent a notice of deficiency
for the 1993 and 1994 tax years to the Millbrae address. On
August 27, 1996, another copy of the notice was sent to
petitioner in Beijing, China. In the notice of deficiency,
respondent determined deficiencies, partly because petitioner
failed to substantiate deductions he claimed on his 1993 and 1994
Federal income tax returns.
On October 11, 1996, petitioner requested that ESP send the
1993 and 1994 administrative files back to respondent’s auditors.
The administrative files were sent back to respondent’s auditors
on October 18, 1996.
On November 12, 1996, Peter Phillips (Phillips),
respondent’s auditor, spent 1 day reviewing petitioner’s
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Last modified: May 25, 2011