- 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 $1,466
Page: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
Last modified: November 10, 2007