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Appeals Officer John Dennis Smith (Mr. Smith) from respondent’s
Appeals Office in Jackson, Mississippi (Appeals) advised
petitioners that he had been assigned their case. However, Mr.
Smith returned the case to the examination division on November
12, 1992, for further development.
Revenue Agent Phyllis Shearer (Ms. Shearer) was assigned to
resume the examination. She met with Mr. Hunter on December 11,
1992, and had several telephone conversations with him after
their meeting. At the conclusion of her examination, Ms. Shearer
prepared a revised revenue agent’s report (the revised RAR). In
the revised RAR deficiencies of $9,032 and $11,853 for the years
1989 and 1990, respectively, are proposed. Petitioners did not
agree with the proposed adjustments contained in the revised RAR
and requested that the case be sent back to Appeals. On March
19, 1993, Ms. Shearer returned the case to Mr. Smith. On April
8, 1993, Mr. Smith notified petitioners that the case had been
returned to him.
By letter dated April 14, 1993, Mr. Smith scheduled a June
14, 1993, conference with Mr. Hunter, but Mr. Hunter failed to
appear. Petitioners retained a different representative, Ernest
D. Kelly (Mr. Kelly), sometime thereafter. Because Mr. Kelly’s
office was in New Orleans, Louisiana, on June 25, 1993,
petitioners requested that their case be transferred to the New
Orleans Appeals Office. Respondent determined that the case did
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