Gerard and Audrey Kathleen Hennessey - Page 34




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          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          $1,466                         






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