- 33 -
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.
Page: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 NextLast modified: May 25, 2011