- 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. Stephenson
Page: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
Last modified: November 10, 2007