- 30 - indicated that this amount included petitioners’ mortgage payments, car loan payments, and payments for home furnishings. Agent Wharton also determined that a majority of shipping expenses were for items shipped to family members for which there was no clear business purpose. On January 12, 2000, Appeals Officer Medina met with petitioners, Ms. Stephenson, and Mr. Rebollo to discuss Agent Wharton’s review and the adjustments he was willing to concede in order to facilitate a possible settlement. Petitioners rejected the settlement proposal. Subsequent settlement proposals by Ms. Stephenson were rejected by Appeals Officer Medina. By letter to Mr. Rebollo dated January 28, 2000, Appeals Officer Medina again explained the results of Agent Wharton’s examination and respondent’s position with respect to the proposed adjustments. In April 2000, petitioners engaged new counsel, W. Thomas Finley (Mr. Finley) to represent them in their dispute. After an April 28, 2000, meeting, Mr. Finley agreed to provide Appeals Officer Medina additional substantiation prior to any decision by the Appeals Office. On June 20, 2000, Mr. Finley sent a new settlement proposal to Appeals Officer Medina, along with additional substantiation and spreadsheets prepared by Ms. Stephenson. In a letter to Appeals Officer Medina dated August 1, 2000, Ms. StephensonPage: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 NextLast modified: November 10, 2007