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petitioner to ascertain petitioner’s position regarding an
Appeals conference that had been scheduled for February 10, 2003.
On January 16, 2003, AO Leduc received petitioner’s written
position. As scheduled, AO Leduc, petitioner and Mr. Schultz met
for an Appeals conference on February 10, 2003. Mr. Schultz
contacted AO Leduc on March 17, 2003, and stated that the
requested documents would be mailed the next day. After
receiving the documents on March 26, 2003, AO Leduc initiated
review of the material on April 1, 2003. After reaching a
decision on April 2, 2003, AO Leduc mailed the decision to
Mr. Schultz and also sent the case to respondent’s technical
section for final computation.
On May 12, 2003, AO Leduc mailed to Mr. Schultz Form
870-AD, Offer to Waive Restrictions on Assessment and Collection
of Tax Deficiency and to Accept Overassessment. After a
telephone call from each party, AO Leduc received the signed
Form 870-AD on June 5, 2003, signed it, and sent it to Appeals
Team Manager Chester Kreidich (ATM Kreidich). On June 5, 2003,
AO Leduc prepared an “Appeals Transmittal and Case Memo.” On
June 12, 2003, ATM Kreidich signed the Form 870-AD.
On July 7, 2003, the Tampa Appeals Office closed
petitioner’s case. The Tampa Appeals Office thereafter sent
petitioner’s case file to the Jacksonville Appeals Office to
complete processing the case. On July 15, 2003, the Jacksonville
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Last modified: March 27, 2008