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On January 23, 1997, Agent Sutton issued an IDR which again
requested, in part, copies of Beacon’s and ISOA, Inc.’s tax
returns for the taxable years in issue, as well as the general
ledgers which support all of the tax returns under examination.
Petitioners requested additional time to comply with the IDR
because of the large volume of documents in petitioners’
possession and the need to review each adjustment on their
“general ledgers”. On February 20, 1997, petitioners requested
additional time in order to reconstruct some records and to put
the 1994 and 1995 taxable years in a general ledger format.
Additionally, Ms. Stephenson notified Agent Sutton and claimed
that during this time petitioner’s work demands were also
“overwhelming to her.”
By letter dated February 10, 1997, respondent denied
petitioners’ request to transfer the examination to respondent’s
Dallas, Texas, office.
On March 10, 1997, Agent Sutton received from petitioner
what have been referred to by petitioners as “general ledgers”.
On March 14, 1997, Agent Sutton received revised general ledgers
for 1994 and 1995. (We have not undertaken to evaluate the so-
called general ledgers as to whether they fall within a normal
definition of “general ledger”. See Webster’s Third New
International Dictionary (1986), which defines general ledger as
follows: “the principal and controlling ledger of a business
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