Garrett Lawrence Bailey - Page 5

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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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