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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
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