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additional information before that conference. On January 18,
2002, Mr. Schultz provided the additional information. On
January 22, 2002, Agent Kelley, Mr. Schultz, petitioner, and
Group Manager Carter attended a conference, at which they could
not agree.
During February 2002, Agent Kelley was temporarily
reassigned. On February 4 and 14, 2002, Agent Kelley informed
Mr. Schultz of the temporary reassignment. Agent Kelley was
temporarily reassigned during parts of February and March 2002.
On March 4, 2002, Agent Kelley contacted Mr. Schultz and worked
on petitioner’s case. On April 17, 2002, respondent determined
that the case should be closed unagreed. On April 23, 2002,
respondent closed the case unagreed.
On May 2, 2002, respondent issued petitioner a Letter 950
(30-day letter) for 1998, 1999, and 2000. On May 31, 2002,
Mr. Schultz requested consideration by respondent’s Appeals
Office. On June 17, 2002, respondent’s Tampa Appeals Office
received petitioner’s file. On June 25, 2002, respondent
assigned petitioner’s case to Appeals Officer Roger Caruso
(AO Caruso) and mailed petitioner a letter informing him of
AO Caruso’s receipt of the case.
On July 5, 2002, respondent sent petitioner a Form 872,
Consent to Extend the Time to Assess Tax, for 1998 and 1999.
Initially, Mr. Schultz informed respondent that petitioner did
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Last modified: March 27, 2008