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documentation regarding the use of the money that he had
borrowed, nor did he produce to Sison a note from the corporation
or other documents which Sison desired. Following the appeals
conference, petitioner wrote a letter to Sison on September 15,
1998, in an attempt to explain his operation. The letter did not
mention the corporation, and it did not discuss the corporation’s
role in the operation. Sison asked John Keegan (Keegan), whom
petitioner had hired to represent him on or about September 15,
1998, to present to Sison the books and records to support
petitioner’s argument. Keegan declined to do so. Following the
Appeals conference, Sison allowed certain reductions in the
adjustments listed in the notice of deficiency. Sison did so
because Sison believed that they had been allowed in the prior
reconsiderations, but not taken into account when the tax was
assessed.
Following the partial abatement of tax pursuant to Sison’s
recommendation, petitioner made a request under the Freedom of
Information Act (FOIA) for a copy of his 1992 and 1994
administrative files. On May 15, 1999, Keegan attended an IRS
“Problem Solving Day” and presented to representatives of the IRS
a narrative as to petitioner’s case. Keegan also presented the
representatives with copies of approximately 500 pages of
documents in the 1992 and 1994 administrative files which he had
received pursuant to the FOIA request. Keegan’s narrative
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