William C. Eberhardt, Jr. and Susan A. Eberhardt - Page 7

                                        - 6 -                                         
          of petitioners' 1995 return as unagreed and forwarded the case to           
          the Appeals Office.                                                         
          B.  Review of Petitioners' Return by the Appeals Office                     
               Petitioners' case file was received in Appeals on or about             
          January 27, 1999, and Appeals Officer Marilyn Radford (Ms.                  
          Radford) was assigned to handle the case.  Petitioners agreed to            
          hold their initial meeting with Ms. Radford on March 19, 1999.              
          On March 18, 1999, petitioners sent her information setting forth           
          their position on the audit.  Ms. Radford asked for a                       
          postponement of the initial meeting so she could review the                 
          information.                                                                
               Ms. Radford held telephone conferences with petitioners on             
          March 24, 1999, and March 26, 1999.  Petitioners complained that            
          the IRS handled their audit unprofessionally and caused                     
          unnecessary delays.  Petitioners also blamed the IRS for allowing           
          a qualified plan to "defraud" its investors and for the resulting           
          loss in the value of their IRA.  Petitioners did not discuss the            
          medical expense issue at all.                                               
               Ms. Radford prepared an Appeals Case Memorandum on April 22,           
          1999, in which she recommended disallowing petitioners' medical             
          expenses for lack of substantiation.  Petitioners provided only a           
          typed list of expenses incurred, not actual receipts or                     
          statements as requested in the IDRs.  Ms. Radford also                      
          recommended disallowing petitioners' claimed casualty or theft              






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011