- 7 - 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 MayPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011