Gerard and Audrey Kathleen Hennessey - Page 28




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          Stephenson as to the general scope and course of the Appeals                
          review process with respect to petitioners.  Appeals Officer                
          Medina also informed Ms. Stephenson as to the categories of                 
          expenses with respect to petitioners, Beacon, and ISOA, Inc.,               
          that would be examined.  Appeals Officer Medina further noted               
          that the examiner would initially apply a sampling technique to             
          review petitioners’ substantiation.  Ms. Stephenson was                     
          subsequently informed by Appeals Officer Medina that any                    
          settlement with respect to petitioners’ 1992 taxable year was               
          irrelevant because each year stands on its own and that each                
          issue raised during the original audit had to be addressed at               
          Appeals.                                                                    
               After discussing petitioners’ case with Appeals Officer                
          Medina, Ms. Stephenson notified petitioners by letter as to                 
          the nature of the Appeals Office review.  Specifically, Ms.                 
          Stephenson informed petitioner that if the sampling process did             
          not yield sufficient results then the examiner might deny a                 
          deduction in whole or in part, or “she will have to look at every           
          item of deduction”.                                                         
               Revenue Agent Jean Wharton (Agent Wharton) was assigned to             
          examine petitioners’ records during the Appeals Office review.              
          Petitioners did not support Appeals Officer Medina’s suggestion             
          to add a second revenue agent to expedite the Appeals                       
          examination.                                                                







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