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January 4, 1995, to commence the examination of KSCI’s 1992
return.
At the January 4 meeting petitioner and Mr. Chang provided
Mr. Matos with copies of KSCI’s bank statements and dividends
received account statements. Mr. Matos then requested that
additional information be supplied by KSCI on or before January
18, 1995.
On April 21, 1995, at the request of his supervisor, Mr.
Matos began to review whether KSCI was a personal holding
company. On April 24, 1995, Mr. Matos and petitioner had a phone
conversation, and petitioner agreed to provide the additional
information previously requested by Mr. Matos. On April 27,
1995, petitioner provided Mr. Matos with that information.
On May 18, 1995, Mr. Matos met with petitioner and asked
petitioner to forward to KSCI’s accountant an additional
information request. On June 29, 1995, petitioner provided
answers to some of the questions in the information request. Mr.
Matos and petitioner scheduled another meeting for August 3,
1995, to review the remaining information requested, and the two
met on that date. On August 7, 1995, Mr. Matos contacted
petitioner and requested a copy of KSCI’s 1993 tax return. Mr.
Matos received a copy of KSCI’s 1993 Form 1120S on August 25,
1995.
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