Gerard and Audrey Kathleen Hennessey - Page 30




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          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. Stephenson                 







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