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information regarding KSCI be supplied on or before January 18,
1995. It was not until April 27, 1995, that petitioner
complied with Mr. Matos’s request for additional information.
Petitioner acknowledges that it was not until April 21, 1995,
that Mr. Matos began to review whether KSCI was a personal
holding company.
The record also indicates that Mr. Matos collected other
information from petitioner throughout the course of his
examination. Nothing in the record indicates that this
information was related solely to the treatment of KSCI as a
personal holding company. During his examination, Mr. Matos
made adjustments to KSCI’s income for omitted capital gain and
dividend income and disallowed certain KSCI expenses. These
adjustments and disallowances were sustained at the
administrative appeal level. The information gathered during
the examination process enabled the Appeals officer to resolve
KSCI’s and the Chans’ 1992 and 1993 deficiency determinations
in a short time.
For the period from October 20, 1997, when the IRS mailed
the Chans final Statements of Account and bills for examination
adjustments, to the present, any interest which accrued on
petitioner’s tax deficiencies was solely due to petitioner’s
failure to pay his outstanding tax liabilities. Petitioner’s
argument that he could have sold his Hong Kong stocks before
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