Gavin Polone - Page 33

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               John Alan Harbin represented petitioner during the                     
          examination of petitioner’s 1996, 1997, and 1998 returns.  Mr.              
          Harbin is an attorney and a certified public accountant.                    
               RA Colline met with Mr. Harbin several times during the                
          examination.  RA Colline issued several Information Document                
          Requests (IDR) to petitioner.  Mr. Harbin was professional, but             
          he delayed several times in responding to the IRS.                          
               RA Colline requested that petitioner sign a Form 12180,                
          Third Party Authorization.  RA Colline requested permission to              
          interview a third party--Mr. Berkus.  Mr. Harbin stated that he             
          would sign the Form 12180; however, over a month passed and he              
          never signed the form.  RA Colline summoned Mr. Berkus and                  
          interviewed him.                                                            
               On July 26, 1999, RA Colline issued an IDR (July 26 IDR) to            
          petitioner.  She received none of the requested documents.  All             
          three items requested concerned the settlement documents for the            
          litigation between petitioner and UTA regarding UTA’s termination           
          of petitioner.  RA Colline did not obtain the information                   
          requested in the July 26 IDR from petitioner.  In October 1999,             
          she obtained this information from Mr. Berkus.                              
               On November 8, 1999, RA Colline issued an IDR (November 8              
          IDR) to petitioner.15  The November 8 IDR requested tax return              
          information regarding petitioner from Hofflund Polone and Bedford           


               15  This document also informed petitioner that his 1997 and           
          1998 tax years were under examination.                                      



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