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the above separation agreements between Haas, DPH, and the other
affected parties.
During the audit, respondent’s revenue agent requested, on a
number of occasions and in writing, petitioners and/or
petitioners’ prior counsel to provide to respondent complete
copies of all of the schedules and exhibits referred to in the
transaction documents relating to the above separation agreement.
During respondent’s audit, neither petitioners nor
petitioners’ prior counsel provided respondent’s representatives
copies of certain schedules of assets and clients that were
identified and referenced in the transaction documents.
On October 21, 1997, respondent’s revenue agent mailed to
petitioners copies of the revenue agent’s reports relating to
Haas and his wife’s 1993 joint Federal income tax liability and
to Haas & Associates’ 1994 and 1995 Federal income tax
liabilities, which reports proposed the underlying tax
adjustments that were decided in our Memorandum Opinion, Haas &
Associates Accountancy Corp. v. Commissioner, supra.
By letter of October 28, 1997, Haas notified respondent’s
revenue agent that he did not agree with the adjustments proposed
in the above revenue agent’s reports, that the audit should be
closed by respondent as unagreed, and that Haas would appeal the
adjustments in court. The relevant portion of Haas’ October 28,
1997, letter to respondent is set forth below:
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