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requested an extension to file respondent’s answer and offered
petitioner an opportunity to meet with the Office of Appeals.
After respondent filed his answer on January 29, 2002,
petitioner, for the first time, requested administrative review.
At the request of the Office of Appeals, the appellate conference
was delayed for several months. On May 20, 2002, petitioner
notified respondent and requested that the conference be delayed.
On June 6, 2002, petitioner informed respondent that petitioner
wanted to reschedule the conference for July 2, 2002. Prior to
June 30, 2002, petitioner was notified several times about
rescheduling the conference, but it was canceled indefinitely
because the case was reassigned. Also, during June 2003,
petitioner proposed an offer titled “Settlement Issues and Offer
of Settlement”, but it was rejected by respondent. On September
8, 2003, the trial was held in Atlanta, Georgia.
On June 21, 2004, in McGowan v. Commissioner, supra, we held
that respondent failed to establish that petitioner intended to
evade tax.
On July 26, 2004, petitioner filed petitioner’s motion for
recovery of reasonable administrative and litigation costs. On
August 30, 2004, respondent filed an objection to petitioner’s
motion for recovery of reasonable administrative and litigation
costs.
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