- 34 - from the most recent “general ledgers” to verify the amounts on the “mockup” tax returns. During his review of the “mockup” tax returns, Agent Laakso occasionally needed to request additional substantiation. After reviewing the “mockup” tax returns, Agent Laakso discussed settlement proposals for each taxable year in issue with Ms. Stephenson. The settlement proposals reached between Agent Laakso and Ms. Stephenson were then submitted to Ms. McIlyar and Mr. Finley to negotiate any possible final settlements. On December 5, 2001, Mr. Finley sent respondent a separate settlement offer for each of the years 1993 through 1996 with total tax liabilities for each year as follows: Total Year tax liability 1993 $5,000 1994 5,450 1995 7,700 1996 1,750 On February 11, 2002, the settlement offers for 1993 and 1994 were accepted by Ms. McIlyar in the amounts proposed by Mr. Finley. On February 19, 2002, Ms. McIlyar proposed settlements for the 1995 and 1996 taxable years as follows: Total Penalty Year tax liability sec. 6662(a) 1995 $12,921 --- 1996 7,330 $1,466Page: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 NextLast modified: November 10, 2007