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request for additional time to gather the documentation, Agent
Sutton extended the time for petitioners’ response to October 1,
1996.
On or about October 1, 1996, petitioners provided Ms.
Stephenson with a box of documentation related to petitioners’
travel activities. This documentation also included petitioners’
1992 return.
On October 1, 1996, Ms. Stephenson met with Agent Sutton and
provided her some documents, including bank statements and charge
card statements, to review with respect to petitioners’ 1992
taxable year. Ms. Stephenson also informed Agent Sutton that
petitioners had been unable to collect some of the requested
documents, including travel receipts and reimbursement
documentation from the University. The meeting between Ms.
Stephenson and Agent Sutton lasted approximately 1 hour.
On October 3, 1996, Agent Sutton issued an IDR which
requested, in part, the “items requested in the original
appointment letter that has [sic] not yet been provided.” The
IDR also requested, in part, all tax returns from petitioners and
Beacon for the taxable years 1991 through 1995 and ISOA, Inc.,
for the taxable years since its incorporation. In addition,
Agent Sutton requested supporting documentation with respect to a
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Last modified: November 10, 2007