Kristin J. Calitri - Page 10

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          of goods sold and business expenses, (2) respondent refused to              
          proceed with the audit unless petitioner agreed to extend the               
          period of limitations to assess the 2000 and 2001 income taxes,             
          and (3) respondent failed to follow certain guidelines under                
          Internal Revenue Manual pt. 4.10.2.2.2 (May 14, 1999), regarding            
          when returns should be examined.                                            
               The Court has reviewed a copy of respondent’s Examining                
          Officer’s Activity Record (Activity Record), copies of                      
          petitioner’s correspondence with respondent, and other relevant             
          evidence, and is persuaded that petitioner had numerous                     
          opportunities, prior to the issuance of the statutory notice of             
          deficiency, to present documentation that would substantiate her            
          cost of goods sold and business expenses.                                   
               According to the Activity Record, petitioner requested and             
          was granted a rescheduling of the initial January 8, 2004,                  
          meeting to February 3, 2004.  On the day before the February 3,             
          2004, meeting, petitioner phoned and left a message with the                
          examining agent to cancel the meeting.  By letter dated February            
          13, 2004, petitioner requested a meeting “after the filing season           
          ends April 15, 2004”, so that her accountant could review her               
          records and prepare for the examination.                                    
               The examining agent made numerous telephone calls to                   
          petitioner during the weeks of March 5, March 12, and March 29,             
          2004, to reschedule the meeting, but petitioner failed to return            
          the calls.  On March 26, 2004, respondent’s group manager left              





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