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From December 21, 2001, to November 17, 2003, an IRS agent
sent to petitioners, collectively and individually, several
letters requesting interviews and scheduling appointments to
discuss their 1998, 1999, and 2000 tax years. Petitioners did
not meet with the IRS agent during that period. On January 6,
2004, petitioners scheduled a meeting with the IRS agent for
January 30, 2004, in Vallejo, California, which location was
chosen for petitioners’ convenience. The agent traveled
approximately 180 miles from Redding, California, to Vallejo for
the meeting, but petitioners failed to appear.
On February 4, 2004, the IRS sent to petitioners summonses
directing them to appear on March 4, 2004, to be interviewed and
to produce documents regarding their 1998, 1999, and 2000 tax
years. Petitioners did not appear on March 4, 2004, or produce
the requested documents. On May 21, 2004, the IRS provided to
petitioners’ counsel copies of document requests previously sent
to petitioners. Petitioners still failed to provide any of the
requested information. On February 11, 2005, petitioners were
served with additional summonses requiring their appearance on
March 1, 2005. The IRS agent again traveled to Vallejo to meet
with petitioners, but petitioners again failed to appear.
In 2002, the IRS began issuing summonses to Redding Bank and
to petitioners’ paint suppliers in order to obtain information
regarding petitioners’ tax liability for the years in issue.
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Last modified: May 25, 2011