JAI'{ 2 8?014. CC : SB :2: GBO: 2: CDCooper TL Via Resular Mail

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1 OFFICE OF THE CHIEF COUNSEL DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE OFFICE OF DIVISION COUNSEL SMALL BUSIN ESS/SELF-EMPLOYED 4905 KOGER BOULEVARD, SUITE 102 ALAMANCE BUILDING, MAIL STOP 24 GREENSBORO, NORTH CAROLINA ( FAX: (336 s JAI'{ 2 8?014 CC : SB :2: GBO: 2: CDCooper TL Via Resular Mail Abdullah Gurhan Kok & Zeynep C. Alkan 506 Westminster Drive Chapet Hill, NC Reference: Abdullah Gurhan Kok & Zeynep C. Alkan v. Commissioner Docket No Dear Mr. Kok and Ms. Alkan: Enclosed is the Answer we filed with respecto the Petition you filed in the U.S. Tax Court. The purpose of this letter is to explain how our office will handle your case. The Office of Chief Counsel, IRS The Office of Chief Counsel serves as legal counsel to the Internal Revenue Service. An attorney from this office will representhe IRS in the U.S. Tax Court if your case proceeds to trial. Now that we have filed our Answer (enclosed, we will forward your case to the IRS Appeals Division so they can explore settlement of your case without trial. Txe lr S A ooea ls Division Tne IRS Appeals Drvrston s goal rs to resolve tax controversies, without lrtrgatron, a fair and impartial basis to both the IRS and the taxpayer, We encourage you to work with Appeals to attempto resolve your case without the need for a trial. lf your case is not resolved by the IRS Appeals Division, it will be transferred back to our office for trial preparation, although we will still attempto resolve your case withouthe need for trial. Your case will be worked by Appeals in the order in which it was received, and please understand it could take approximately days for assignment to an Appeals Officer/Settlement Officer. Once your case is assigned to an Appeals Officer, you will be contacted by him/her to set up a telephone or in-person conference to discuss settlement.

2 Docket No. TL ontact Your case is being handled by: Appeals Office. Philadelphia Attn: Lead ATM Internal Revenue Service 600 Arch Street, Room 6448 Philadelphia, PA lf you have not heard from the IRS Appeals Division within 90 days from the date of this letter, you may contact us so that we may assist you in determining which ^'u ^er,settlement,at,.f.ucl \-/lllur Officer is assigned to your case ano provide you their phone number. lf your case has not been assigned in Appeals, we will provide you with rnformation about when your case assignment can be expected. lf you do not settle vour case with the IRS Appeals Division lf you are unable to reach a settlement with the IRS Appeals Division, your case will be transferred back to this office for trial preparation. You will be contacted by an attorney and/or paralegal by letter and/or phone to discuss the facts of your case, and he/she may ask you for additional documents or information to prepare the case for trial in the U.S. Tax Court. We will also be required to prepare a Stipulation of Facts which is a document signed by both parties that sets forth all the facts and/or documents that are not in dispute. This document will help the Court to decide your case. Other useful information Within the next few months, you can expect to receive a Notice Setting Case for Trial from the U,S. Tax Court stating that your case rs set for a specific trial calendar date. lf you are working with Appeals when you receive this notice, we encourage you to continue to do so in an effort to resolve your case well in advance of the trial date set. lf the case has already been transferred to our office for trial preparation, w will work with you to prepare your case for the trial on the calendar date. The filtng of a bankruptcy may affecthe court's jurisdiction in this case. lf you have recently been in bankruptcy, please notify me so that I can consider how this may affect your case. Also, if you believe that you already resolved your case with the lrs, please notify me and be prepared to provide me with copies of any correspondence you have which so indicates. This will enable me to determine how to proceed with your case.

3 Docket No TL lf you have any questions that are not answered by this letter, you may contact me at ( Sincerely, Paralegal Specialist Greensboro, Group 2 (Smal I Busi ness/self-employed Enclosu re: Answer

4 UNITED STATES TAX COURT ABDULLAH GURHA}T KOK & ZEYNEP C. ALI(AN, Petitioners, V. Docket No S COMMISSIONER OF INTERNAL REVENUE, filed Electronically Respondent.. \IVSWER RESPONDENT, in answer t.o t.he petit.ion filed in t,he aboveentit.l-ed case, admits, alleges, and denies as f olrows : 1. Admit.s. 2. Admit,s. 3. Admit.s. Alleges respondent has also assert.ed. a penalt,y pursuant, to I.R.C. S 6662(a of $L, a. Admits that, respondent. determined that petit.ioners received unreported nonemployee compensat.ion in the amount. of -':: :::.:: irc:.3. F. Aerospace rnc. for Li:e taxabre vear 2a!\, :=:- es ::-a: :ite ce:er::ti:ta:ro:ts - s ettoltec;s. r-en- es a..j,- remaj-ning allegation for lack of current. knowledge or sufficient. information. b. Admits, except. denies any amounls have been assessed.. Alleges t,he penart.y is assert,ed pursuant t,o r. R. c. s 6662, not. r.r.c. s 666r.

5 Docket No S f,. a. Admits that petitioners received unreported nonemployee compensation from B. E. Aerospace Inc. for the taxable year 20LI. Denies all remaining allegations for lack of current knowledge or sufficient information to form a belief as to the truth of the al- leqations therein. b. and c. I inciusive, ctenies f or iack of curi-ent knowledge or sufficient information to form a belief as to the truth of the allesations therein. d. Admits that respondent mailed to petitioners a notice of deficiency on September 3, 2013, reflecting an increase in tax f or the taxabl-e year 20I\. Further admits respondent' s receipt of a copy of a corrected Form 1099-Misc reflecting $10, in nonemployee compensation for the taxabl-e year 20II. Alleges that respondent is researching this case to determine the validity of petitioners' allegations but has not been able to make that determination at this time. Denleq all r m-'i ^'i -^ ^ I 'r ^^-r 'i ^*s f or lack of currenf knowl edoe or ICIIIdIIIIII\I C1 IIgVOLI\JIID I-\JI. -LAUJ\ \JL \-L.TIIEI.IL ^.t.i\jwtg\.iy sufficient information to form a belief as to the truth of the allegations therein. Denies that there is an Exhibit B attached to the copy of the petition served upon counsel- for respondent. Further denies any alleged errors.

6 Docket No S 5. Denj-es generally each and every al-l-egat.ion of the petition not herein specif ica1iy admit,ted, qualif ied or denied. WHEREFORE, it is prayed that t.he relief sought in the petition be denied and that respondent's determinat.ion, a.s set forth in the nolice of deficiency, be in all respects approved. WTLLIAM J. WiLKTIIS Chief Counsel- Internal Revenue Servi-ce Dare, f fplir4 Associate Area Counsel ( Small Busine ss / Self -Employed Tax Court, Bar No. DAO Koger Boulevard, Suite 1-02 Alamance Building, Mail Stop 24 Greensboro, NC Telephone: ( OF COUNSEL: THOMAS R. THOMAS Division Counsel ( Small Busine ss / Seff -Employed NANCY B. ROMANO Area Counsel (Smal1 Business /Self -Employed:Area 2

7 Docket, No S CERTIFIEATE OF SERVICE This is to cerlify that a copy of the foregoing ANSWER was served on petit.ioners by mailing the in a postage paid wrapper addressed same on as follows: JAN 2 8 Zat4 Abdull-ah Gurhan Kok & Zeynep C. A1kan 506 West,mi-nst.er Drive Chape1 HilL, NC 2751, Dat.e : -iat'{ g E Z$14 AMY DYAR Associat,e Area Counsel (Greensboro, Group 2 (Small Busine ss / Sel-f - Employed Tax CourL Bar No. DAO 275