Chester H. and Michelle R. Rossman - Page 7

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               Petitioner stated that there was no letterhead page attached           
          to the letter when both petitioner and Mr. Marshall signed the              
          letter.  Therefore, petitioner postulated that an associate, Jim            
          Jensen (Mr. Jensen), also involved in TSG, sent the letter to               
          Agent Riley substituting a retyped page one containing Mr.                  
          Marshall’s letterhead.  Mr. Jensen was not called and did not               
          testify at trial.                                                           
               Continuing his audit examination, in the absence of tax                
          returns or tax documents, Agent Riley issued summonses to banks             
          and mortgage companies in an attempt to obtain petitioner’s                 
          financial information.  However, Agent Riley was unable to                  
          procure petitioner’s financial information because there were no            
          bank accounts in petitioner’s or his wife’s name.  Agent Riley              
          then reconstructed petitioner’s income using Bureau of Labor                
          Statistics information and sent his examination report to                   
          petitioner around the end of 1999.  Petitioner responded by                 
          filing a protest and a request to go to the Salt Lake City, Utah            
          IRS Office of Appeals.                                                      
               Petitioner stated that he was confused as to whether he                
          should file a Form 1040, U.S. Individual Income Tax Return, or a            
          Form 2555.  He testified that Agent Riley asked him “to fill out            
          1040 returns” but that petitioner’s “studies” showed the form               
          used by the Office of Management and Budget that was “assigned              
          [to] collect the tax on income” appeared to be Form 2555.  On May           






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