-6-
copies of Forms 1099 for interest paid to investors, or an
explanation why no Forms 1099 were filed or required. On
November 25, 1996, Jones responded to part of the IDR by
telephone and indicated that he would call Carter back on the
next day with other information. Jones never did so. Carter
closed the case with no change to the adjustments detailed in the
notice of deficiency.
Petitioner did not petition this Court with respect to the
notice of deficiency, and, on February 10, 1997, respondent
assessed the deficiency shown in that notice. Approximately 2
months later, petitioner asked the Commissioner to reconsider the
adjustments underlying that deficiency. On March 4, 1998, Dennis
Duggan (Duggan), a revenue agent, notified petitioner that Duggan
was assigned to reconsider those adjustments and requested from
petitioner the books and records of the sole-proprietorship and
the corporation. Petitioner and Duggan met on June 11, 1998.
Petitioner did not provide the requested books and records (or
any other new information) to Duggan. Duggan concluded his
reconsideration with no change and forwarded the case to Appeals
for its consideration.
Lydio Sison (Sison), an Appeals officer, considered the case
on behalf of Appeals. During a conference with Sison, petitioner
discussed the role that his corporation played in his operation.
Petitioner did not at the conference produce to Sison
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