Paul McGowan - Page 3

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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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