- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011