Tae M. & Young J. Kim - Page 5




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          a total of $21,267 as “Gross proceeds” ($21,267 of gross pro-               
          ceeds) from broker transactions described as “EMP PLN SHRS SOLD”.           
               Petitioners timely filed a petition with the Court with                
          respect to the 2002 notice.  In the petition, petitioners alleged           
          in pertinent part: “The petitioners disagree with IRS in the                
          determination of the deficiency because it was based on the                 
          insufficient and inaccurate information.”                                   
               On September 16, 2004, respondent filed an answer.  In the             
          answer, respondent denied that the determinations in the 2002               
          notice were incorrect and requested “that the relief sought in              
          the petition be denied and that respondent’s determination, as              
          set forth in the notice of deficiency, be in all respects ap-               
          proved.”                                                                    
               At various times not disclosed by the record after petition-           
          ers filed the petition in this case, respondent made requests to            
          petitioners for information about the $21,267 of gross proceeds             
          shown in the EquiServe Forms 1099-B.  Petitioners did not provide           
          any information or explanation in response to those requests.               
               As discussed above, respondent included in the 2002 notice             
          the address of each payer who provided respondent with an infor-            
          mation return with respect to Mr. Kim or Ms. Kim, including the             
          address of Equiserve shown in the EquiServe Forms 1099-B and the            
          account number for Ms. Kim shown in those forms.  Nonetheless, on           
          August 24, 2005, petitioners sent respondent a letter that stated           







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Last modified: November 10, 2007