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1997 returns a Schedule C, Profit or Loss From Business, for Copy
Care Technology. He deducted business expenses of $56,500 for
1996 and $97,752 for 1997 on the Schedules C.
D. Respondent’s Examination of Petitioner’s 1996 and 1997
Returns
Revenue Agent Colleen Warren (Warren) began her examination
of petitioner’s 1996 and 1997 returns in December 1998, when she
met with petitioner at his home. He refused to talk to Warren at
that time. Warren then invited petitioner to meet with her at
her office. She asked petitioner for copies of his 1996 and 1997
bank statements, invoices, and canceled checks to support his
1996 and 1997 Schedule C expense deductions. Petitioner did not
respond to Warren’s December 1998 document requests, meet with
her, or respond to her telephone calls. She sent petitioner
several letters to attempt to schedule a conference. Petitioner
did not respond to these letters. Warren also gave petitioner
the option of meeting instead with her manager, but petitioner
refused.
Petitioner told Warren that he could not understand English.
Warren then asked a revenue agent who spoke Vietnamese to contact
petitioner. Petitioner asked that agent to contact him at
petitioner’s mother’s home. The agent left a message there for
petitioner to telephone the agent. Petitioner did not return the
agent’s call.
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