-4-
date of May 23, 1996. Petitioner first delivered some of the
information to the Commissioner on June 4, 1996.
On July 15, 1996, Christian met with petitioner’s
representative, Dan Jones (Jones). Jones did not have a power of
attorney from petitioner, and Christian declined to discuss with
him the specifics of petitioner’s case. Christian later issued
to petitioner a second IDR requesting a breakdown of his Schedule
C gross receipts. Whereas this IDR requested a reply by July 25,
1996, the Commissioner received the requested information on
August 12, 1996. On August 13, 1996, Christian revised her
examination report to reflect that information and sent the
revised report to petitioner with a notice advising him that he
could respond to the revised report within 10 days. Petitioner
did not respond to the revised report. On September 9, 1996, the
Commissioner issued to petitioner a notice of deficiency that
reflected the adjustments in the revised report.
Petitioner subsequently requested from the Commissioner
further consideration of his 1994 tax return. The Commissioner
honored that request by scheduling a meeting for October 22,
1996. At the scheduled time, petitioner met with a tax auditor
named Shirley Finn (Finn). Petitioner gave to Finn: (1) A rough
explanation of his sole-proprietorship’s business, but not
containing any reference to the corporation or to the flow of
funds from the investors to the developers, and (2) certain other
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011