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a meeting on August 26, 1994, Mr. Runkle responded that he was
unavailable to meet on the scheduled date. Mr. Runkle did not
propose an alternative date. Similarly, when Revenue Agent
Andrews issued an examination letter to Mrs. Runkle for 1991,
1992, and 1993, Mrs. Runkle neither appeared at the scheduled
appointment nor rescheduled the appointment.
In response to the revenue agent’s summons directing Mrs.
Runkle to produce her books and records for 1991, 1992, and 1993,
Mr. Runkle advised Revenue Agent Andrews that Mr. Runkle would
accompany Mrs. Runkle to her summons appointment. Four witnesses
who refused to disclose their identities also attended the
summons conference with petitioners. At petitioners’ request,
both petitioners and Revenue Agent Andrews taped the summons
conference. At the summons conference, Mrs. Runkle demanded that
Revenue Agent Andrews provide her with his personal residence
address as a prerequisite to her complying further with the
summons. When Revenue Agent Andrews refused to provide his
personal address, Mrs. Runkle advised him that the summons
conference was done as far as she was concerned. She also
advised Revenue Agent Andrews that she did not bring any books
and records with her.
At the summons conference, Mr. Runkle demanded that Revenue
Agent Andrews provide him with the Code section that makes him
liable for taxes, to which Revenue Agent responded that section
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Last modified: May 25, 2011