Dallas R. Hall - Page 6

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          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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