Ouan Bland - Page 5

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          the checks were cashed at Mr. Fullen’s request, and the proceeds            
          were transferred to him.                                                    
               The parties filed a Joint Motion for Continuance of Trial so           
          respondent could investigate petitioner’s claims and issue a                
          notice of deficiency to Mr. Fullen.  Mr. Fullen gave his Social             
          Security number to respondent.  Respondent’s subsequent                     
          investigation revealed there was no record in respondent’s                  
          internal computerized system of the Social Security number Mr.              
          Fullen provided.  Further, there is no record of Mr. Fullen                 
          having filed Federal income tax returns between 1991 and 2001.              
               Petitioner failed to respond to respondent’s attempts to               
          obtain additional information.  Respondent sent petitioner two              
          certified letters and left 14 messages over the course of a 6-              
          week period.  Petitioner did not respond to any of respondent’s             
          attempted contacts.                                                         
               Mr. Fullen was an independent contractor salesman for SAKB.            
          The checks were supposed to have been made payable to him.                  
          After Mr. Fullen lost his identification, SAKB began making the             
          checks payable to petitioner so that Mr. Fullen would have a                
          vehicle through which he could receive his earnings.  Mr. Fullen            
          explained these circumstances to respondent sometime in July                
          2002.  During respondent’s investigation of this matter, SAKB               
          provided contradictory verbal statements to respondent regarding            
          who performed the services in question.                                     

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