Thomas R. Camerato - Page 3




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               On or about September 7, 1994, respondent sent a notice to             
          petitioner at his Pittsburgh residence address that respondent              
          would audit petitioner’s 1992 Federal income tax return.                    
               On September 9, 1994, petitioner telephoned respondent’s               
          Pittsburgh, Pennsylvania, office to demand that the audit be                
          postponed until May 1995 and transferred at that time to                    
          California, because petitioner’s business expense records were              
          stored in California and it would be inconvenient and expensive             
          for petitioner to retrieve them.  Petitioner indicated that he              
          intended to graduate from school and move back to California in             
          May 1995.  Respondent refused to delay the audit until May 1995.            
               On October 25, 1994, respondent notified petitioner that               
          petitioner’s 1993 Federal income tax return would also be                   
          audited.                                                                    
               Between September and November 1994, petitioner had several            
          further telephone conversations with respondent’s personnel.                
          Petitioner demanded that respondent stop sending him                        
          “threatening” letters, indicated that he would not cooperate with           
          the scheduled audits, and again indicated that he wanted to have            
          the audits delayed to May 1995 and transferred to California.               
               Because petitioner did not appear for an examination or                
          submit documentary evidence to support his deductions, respondent           
          on April 4, 1995, sent petitioner, at his Pittsburgh residence              
          address, by certified mail, a notice of deficiency for 1992 and             






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