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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 case
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