- 28 - 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.Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 NextLast modified: November 10, 2007