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Internal Revenue Service administrative file, but the
administrative file was not introduced into evidence.
According to the version of events presented by respondent
at trial, Ms. Wong had no involvement in or knowledge of this
case outside of reviewing petitioner’s administrative file for
the purpose of testifying. On the basis of this review, Ms. Wong
testified respondent began investigating petitioner when Heath &
Associates reported it paid petitioner non-employee compensation
of $15,800 in 1996 and no corresponding return was filed by
petitioner in 1996. To determine whether petitioner filed a
return under another name, respondent sent petitioner an initial
contact letter, to which petitioner failed to respond.
Ms. Wong further testified respondent prepared a substitute
for return and sent a 30-day letter and a no-response report to
petitioner, to which she did not respond. Next, respondent
issued a statutory notice of deficiency for tax year 1996 to
petitioner based upon the compensation paid to her by Heath &
Associates.
During cross-examination as well as direct, Ms. Wong’s
responses appeared evasive. It was also readily apparent she was
unfamiliar with the case and unprepared to provide any insight
outside of what she could recall from reading the file.
Furthermore, respondent did not provide documentary evidence
to support Ms. Wong’s testimony or to show compensation was paid
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