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documents. Phillips attempted to organize and analyze the
documents submitted by petitioner. However, without petitioner’s
explanation and assistance Phillips found it difficult to review
and understand the documents. After spending a day reviewing the
case, Phillips discussed his difficulties with Gee. Gee decided
that Phillips should not spend any more time reviewing the
documents. As a result of Phillips’ review, respondent issued a
supplemental report for 1993 that allowed a substantial portion
of petitioner’s claimed Schedule C, Profit or Loss From Business,
expenses. The supplemental report did not make any adjustments
to petitioner’s 1994 tax year. Petitioner in writing disagreed
with the supplemental report, offered to meet with respondent’s
representative, and then filed a petition with this Court on
January 24, 1997.
C. Post-Petition
Respondent filed an answer to the petition in the case
concerning the 1993 and 1994 years on March 7, 1997, and filed an
answer to the petition in the case concerning the 1992 year on
May 16, 1997. In both answers, respondent maintained the
positions taken in the notices of deficiency.
On June 25, 1997, and June 27, 1997, Ms. Geraldine Melick
(Melick), an Appeals officer, met with petitioner regarding both
cases. At the meeting petitioner explained many matters that
were not evident from his records. First, he described the
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