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Thank you for your cooperation; and if you have
any further questions please contact me * * *.
Sincerely,
Fred R. Rawley
Appeals Officer
On April 6, 1996, respondent served summonses on Charles and
Gladythe with respect to their 1993 gift tax liability. Shortly
thereafter, the couple retained attorney Larry Johnson (Mr.
Johnson) to represent them with respect to respondent’s
examination. On December 5, 1996, respondent’s examiner proposed
an alternative theory conceding that the Rathbun children, along
with their parents, were members of an informal partnership on
January 11, 1993, but that the children “gifted” a portion of
their interests in the lottery winnings to Charles and Gladythe
upon creation of the limited partnership. Faced with
respondent’s new argument, the Rathbun children also retained Mr.
Johnson in February of 1997.
On September 8, 1999, respondent issued additional 30-day
letters to Charles and Gladythe that mirrored the argument
outlined in the 1995 30-day letters. On the same day, respondent
issued individual 30-day letters to the Rathbun children that
advanced the alternative theory.
On November 10, 1999, Mr. Johnson filed a written protest to
the 30-day letters, and the case was reassigned to respondent’s
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Last modified: May 25, 2011