Royce A. Ellis - Page 5

                                        - 5 -                                         
               complete the examination.  I am requesting that the                    
               power of attorney for Mr. John W. Townshend be                         
               bypassed, as his apparent non-cooperation and lack of                  
               communication is delaying and hindering the examination                
          On January 3, 2003, Agent Bok’s request to bypass Mr. Townshend             
          and to contact petitioner directly was granted.  Neither                    
          petitioner nor Mr. Townshend received notice of respondent’s                
               On January 24, 2003, respondent issued to petitioner a                 
          notice of audit with Form 4564, Information Document Request,               
          informing petitioner his 2001 tax year was under examination and            
          requesting he provide books, records, and other documentation               
          with respect to Coastal Builders.  At a March 24, 2003, meeting,            
          between Mr. Townshend and Agent Bok, Mr. Townshend provided a               
          2001 general business ledger for Coastal Builders.  The ledger              
          had been prepared for the audit because petitioner did not keep             
          contemporaneous books and records of Coastal Builders’ business             
          income and expenses.  Although Agent Bok and Mr. Townshend                  
          discussed 1999 and 2000, no documentation was exchanged.                    
               On June 23, 2003, during the audit, respondent’s Service               
          Center in Ogden, Utah (Ogden Service Center), mailed a CP-2501              
          letter to petitioner indicating that JPI filed four Forms 1099-             
          MISC showing petitioner received $5,704,041 from JPI in 2001.               
          The letter requested information explaining a discrepancy between           

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next 

Last modified: November 10, 2007