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related penalty under section 6662 against petitioners.
Petitioner also failed to attend conferences with Appeals
even though the conferences were scheduled at locations most
convenient to petitioner. Petitioner gave the same excuses to
Appeals that he had given to respondent’s examiner. At all
times, petitioner insisted that he had the documents to
substantiate his Schedule C, Profit or Loss From Business, and
Schedule E, Supplemental Income and Loss, deductions.8 He just
needed more time to locate the documents. Petitioner never
presented the substantiation to respondent despite the 4 years
petitioner had since the audit began in 1999.
Petitioner’s actions and excuses continued even after
respondent’s counsel became involved in the case. Respondent
scheduled an informal discovery conference in respondent’s office
and asked petitioner to produce certain documents. Petitioner
failed to attend the conference and failed to contact respondent
to reschedule until after petitioner missed the conference.
Respondent’s counsel filed a Motion to Compel Production of
Documents and Impose Sanctions with this Court on July 25, 2003.
7(...continued)
that petitioners’ gross receipts should be increased by $1,296,
not $88,587.
8 If petitioner met with the examiner or later with Appeals
for the “purpose of having a substantiation conference,”
petitioner promised to provide additional documentation typically
within 30 days of the conference but would fail to provide the
documentation promised.
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Last modified: May 25, 2011