Phillip and Gladies Aaron - Page 7

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          individual and corporate amended returns for 1997 and 1998 and              
          filing of an appropriate revocation of BP Concessions’ S                    
          corporation election in exchange for withdrawal of the notice of            
          Federal tax lien.  In May 2001, petitioner gave Ms. Jaffe amended           
          individual income tax returns but stated they were never filed.             
          On May 22, 2001, petitioner and Mr. Foster executed an “Agreement           
          to Change BP Concessions to a C Corporation”.  The agreement                
          stated:                                                                     
                    The undersigned hereby agree that at the year-end                 
               meeting in December of 1996, Phillip Aaron was charged                 
               by the Corporation with converting BP CONCESSIONS, INC.                
               from a Sub-Chapter S Corporation to a C Corporation for                
               the specific purpose, and in anticipation of, BP                       
               CONCESSIONS, INC., receiving income and loaning part of                
               that income to Bernie Foster and Phillip Aaron during                  
               the year of 1997.  Phillip Aaron was responsible for                   
               changing the Corporation from a Sub-Chapter S to a C                   
               Corporation.  Phillip Aaron developed cancer and                       
               underwent chemotherapy during 1997 and, as a result,                   
               the C Corporation election was not made.  It is still                  
               the desire of BP CONCESSIONS, INC., Phillip Aaron, and                 
               Bernie Foster that BP CONCESSIONS, INC., be changed                    
               from a Sub-Chapter S Corporation to a C Corporation and                
               that the disbursement of proceeds for 1997 be                          
               classified as a loan as they were intended to be at the                
               time of disbursement.                                                  
               Appeals Settlement Officer Vander Linden prepared a detailed           
          Appeals case memo evaluating petitioners’ appeal and recommending           
          that it be denied.  On July 6, 2001, the IRS issued a Notice of             
          Determination Concerning Collection Action(s) Under Sections 6320           
          and 6330.                                                                   








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