Kristin J. Calitri - Page 11

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          petitioner a voice message stating that a statutory notice of               
          deficiency for 2000 and 2001 would be issued if petitioner failed           
          to contact respondent by April 1, 2004.  The examining agent made           
          several more attempts to contact petitioner during the week of              
          April 5, 2004.                                                              
               The Activity Record further indicates that on April 8, 2004,           
          petitioner informed the examining agent by phone that she                   
          declined to extend the assessment period and that she wanted to             
          schedule a meeting on May 3, 2004.  This is corroborated by                 
          petitioner’s followup letter dated April 8, 2004, where she                 
          stated that both she and her accountant would be available on May           
          3, 2004, and that the additional time would give her accountant             
          an opportunity to review her records as her accountant was not              
          the original preparer of the returns.                                       
               The examining agent agreed to a May 3, 2004, meeting.  The             
          Activity Record indicates, however, that petitioner appeared                
          without her accountant on the date of the meeting.  While                   
          petitioner could have produced the books and records requested by           
          respondent at the May meeting, she did not do so.  According to             
          the Activity Record, petitioner told the examining agent that she           
          needed 3 additional weeks to produce the books and records,                 
          because her accountant was on vacation.                                     
               Respondent’s position in the statutory notice of deficiency            
          of June 29, 2004, premised the adjustments primarily on                     
          petitioner’s lack of substantiation.  Tax deductions are a matter           





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