- 5 - Petitioner subsequently sent to respondent copies of one registration form and one check, with no explanation of the nature or business purpose of the expenses reflected in the documents. By letter dated March 6, 2001, respondent notified petitioner that he had completed the audit reconsideration of petitioner’s 1995 tax liability with no change. In the letter, respondent stated that “The information you have furnished to date, including to the district office does not establish that any of the claimed expenses were ordinary and necessary and incurred in the course of a trade or business.” Respondent also notified petitioner that he could request an Appeals conference if he disagreed with respondent’s decision. By letter dated April 1, 2001, petitioner appealed respondent’s findings. Petitioner’s appeal was assigned to Appeals Officer Willard A. Stone (Mr. Stone). By letter dated June 25, 2002, Mr. Stone advised petitioner that he had scheduled a conference for July 25, 2002, and that petitioner should bring certain enumerated documents to the conference. At petitioner’s request, the conference was rescheduled for August 23, 2002. Petitioner did not attend the August 23, 2002, conference and did not supply the requested documentation. By letter dated September 13, 2002, Mr. Stone notified petitioner that petitioner had not established his entitlement to any of the deductions disallowed in the notice of deficiency, that petitioner’s casePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011