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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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