Carolyn B. Cooper - Page 3




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          C, we will provide sufficient documentation to essentially permit           
          you to accept my 1993 form 1040, as filed."                                 
               In a letter dated August 21, 1996, petitioner submitted to             
          respondent a second set of documents to substantiate her claimed            
          1993 deductions for what she now referred to as an 8-month year.            
          Petitioner advised respondent that "most of [her] original                  
          documents have been displaced or destroyed."  She asked                     
          respondent to "extrapolate" and make estimates.  She stated that            
          she only had 2 months of electric and gas invoices and                      
          substantiation of these expenses would be forthcoming upon                  
          receipt of copies of statements from the respective utility                 
          companies.                                                                  
               In a letter dated November 25, 1996, petitioner stated that            
          she enclosed a copy of a Form 872, Consent to Extend the Time to            
          Assess Tax, so that she could obtain additional information.                
               In a letter dated January 6, 1997, the District Director               
          informed petitioner that the period of time in which the Service            
          might assess tax for the tax period ended December 31, 1993, had            
          been extended to April 15, 1998.                                            
               On April 24, 1997, respondent mailed a notice of deficiency            
          to petitioner.  In the notice, respondent determined a deficiency           
          in the amount of $5,495 in petitioner's 1993 Federal income tax.            
          The deficiency was based on disallowance of itemized deductions,            
          the cost of goods sold, and Schedule C expenses.  The notice of             
          deficiency stated that the miscellaneous deduction was disallowed           



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