-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 SisonPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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