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started the examination of petitioner’s 2000 tax return.
On October 31, 2001, Agent Kelley prepared notices of proposed
adjustment to items reported on petitioner’s return for that
year.
Agent Kelley, her supervisor, Group Manager Patricia Carter
(Group Manager Carter), petitioner, and Mr. Cloud held a
telephone conference on November 7, 2001. The parties to the
telephone conference agreed that Mr. Cloud had until November 23,
2001, to decide whether the case should be closed unagreed.
On November 14, 2001, petitioner retained Fred Schultz
(Mr. Schultz) as his representative. On November 20, 2001,
Mr. Schultz contacted Agent Kelley by phone and faxed her a
power of attorney form.
On December 7, 2001, Agent Kelley prepared a notice of
proposed adjustment regarding petitioner’s return for 2000. On
December 17, 2001, Agent Kelley continued working on the case.
On December 18, 2001, Agent Kelley prepared notices of proposed
adjustment to items reported on petitioner’s returns for 1998 and
1999. During early January 2002, Agent Kelley faxed Mr. Schultz
a revised Revenue Agent Report and scheduled a conference with
Mr. Schultz for January 10, 2002. At the January 10, 2002,
conference, Agent Kelley and Mr. Schultz could not reach an
agreement. Consequently, Agent Kelley and Mr. Schultz scheduled
a subsequent meeting, and Mr. Schultz agreed to provide
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Last modified: March 27, 2008