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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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