Omnitec Corporation, An Administratively Dissolved Corporation, Leland V. Lammert, President - Page 6

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         other two corporations, including petitioner, did not file                   
         Federal income tax returns.                                                  
              At some point, Mr. Lammert was contacted by an agent of the             
         IRS requesting a conference with respect to Omnitec for one of               
         the tax years at issue.  Presumably, this would have been Omnitec            
         Nevada because that was the only one of the three corporations               
         that had filed income tax returns.  Mr. Lammert declined that                
         request.  The agent followed up with a second request, and that              
         request was also declined.  At that point, the agent decided that            
         respondent would proceed to an audit of fiscal years ending                  
         September 30, 1998, and September 30, 1999, the fiscal years on              
         the returns filed by Omnitec Nevada.  Summonses were served on               
         two banks that maintained accounts for Omnitec Missouri and L.V.             
         Properties, Inc.  One of the accounts of L.V. Properties, Inc.,              
         at one of the banks bore the same employer identification number             
         as Omnitec Missouri, No. 43-1215073.  At the other bank, another             
         account for L.V. Properties, Inc., had an invalid number.                    
              The agent then followed up by contacting several customers              
         or businesses that had engaged the services of Omnitec, and, at              
         the agent’s request, these businesses provided approximately 71              
         invoices or bills that had been issued to them for services                  
         provided by Omnitec during the years in issue.  None of these                
         invoices explicitly identified the services as having been                   
         provided either by Omnitec Nevada, L.V. Properties, Inc., or                 






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