Robert L. and Joanne Tammaro - Page 7




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          that EIP and BTQH were organizationally and economically                    
          interrelated and that for the purpose of section 183(d) they                
          constituted one activity.                                                   
               On November 26, 1997, petitioner filed a timely petition               
          with the Court disputing the deficiency in tax for 1994, as well            
          as the additions to tax and accuracy-related penalties for 1993             
          and 1994, as determined in the notice of deficiency.  Respondent            
          filed an answer on January 9, 1998.                                         
               On January 5, 1998, respondent’s counsel mailed petitioner a           
          letter requesting him to attend a conference and to produce                 
          relevant documents relating to the case on January 28, 1998.                
          Petitioner did not appear for the January 28th conference.                  
          Rather, petitioner informed respondent’s counsel that he was busy           
          with the tax filing season and requested a conference at a later            
          date.  In March 1998 another conference was scheduled for June              
          1998.                                                                       
               On the day of the scheduled June conference, petitioner                
          canceled the conference for the expressed reasons that it would             
          be too burdensome for him to transport his records to                       
          respondent’s office in Philadelphia and because he did not want             
          to incur travel expenses for his representative, Theresa Thery              
          (Ms. Thery).  Ms. Thery is an employee at petitioner’s accounting           
          firm.                                                                       








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