Haas & Associates Accountancy Corporation - Page 5




                                        - 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

Last modified: May 25, 2011