Alec Jeffrey Megibow - Page 9

                                        - 9 -                                         
          supporting Schedule C items for car and truck expenses,                     
          professional dues, telephone and communications, local travel,              
          and CPE.                                                                    
               Meanwhile, Schedule C deductions had likewise become a focus           
          of the audit for 1998 and 1999, as evidenced by a Form 4564 dated           
          May 14, 2001, identified as “Request Number 2” for 1998 and 1999,           
          requesting documentation with respect to, inter alia, “All                  
          Business expenses listed on Schedule C for both years” and “All             
          travel and entertainment expenses for both years listed on                  
          Schedule C including a diary showing your travel itinerary”.                
               On January 22, 2002, a final examination meeting was held              
          with Mr. Gendler.  The record indicates that as of that date,               
          petitioner had not provided further materials responsive to the             
          above-described requests for substantiation.  At the meeting, Mr.           
          Gendler, acting under direction from petitioner’s counsel,                  
          Anthony Bentley (Mr. Bentley), declined to consent to an                    
          extension of the time for assessment.  As a result, a decision              
          was made to close the case based on the impending statute of                
          limitations.  Shortly after the meeting, Mr. Gendler apparently             
          provided copies of Amex statements for 1997 and certain bank                
          statements, but these items were not analyzed or incorporated in            
          the adjustments on account of the decision to close the case.               
               The notice of deficiency underlying this proceeding was                
          issued on February 25, 2002.  Among other things, the notice                






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