- 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 Next
Last modified: November 10, 2007