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Sutton (Agent Sutton) was responsible for the examination of
petitioners’ 1992 taxable year. As part of the initial
examination for 1992, Agent Sutton requested that petitioners
provide, among other items, their 1991 through 1993 tax returns.
Respondent also scheduled an appointment in August to meet with
petitioners and discuss the examination.
Petitioners engaged Carolyn Stephenson (Ms. Stephenson), a
certified public accountant, to represent them during their
examination. Ms. Stephenson did not prepare petitioners’ 1992
return, nor did she request to see petitioners’ 1992 return.
In their initial discussion Ms. Stephenson advised Agent
Sutton that some of petitioners’ documents had been lost or
misplaced. Agent Sutton allowed petitioners until August 21,
1996, to gather the documents originally requested.
On July 9, 1996, Agent Sutton issued to petitioners an
Information Document Request (IDR) which requested, in part, that
petitioners provide by August 21, 1996, their individual tax
returns for the 1991 through 1995 taxable years, as well as
Beacon’s tax returns for the taxable years 1991 through 1995. In
addition, the IDR requested “books, records, invoices, receipts,
statements, and any other data to verify” income and expenses
with respect to petitioners’ 1992 tax year. At petitioners’
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