- 6 - 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’sPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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