- 5 - 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:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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