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as exhibits A and B to respondent's objection are the two
exhibits (referred to in paragraph (a) of the explanation of
adjustments portion of the notice of deficiency) that respondent
failed to attach to the notice of deficiency issued to
petitioner.5
Petitioner subsequently filed a Motion to Strike specific
portions of respondent's objection. In particular, petitioner
requests that we strike any reference to exhibits A and B
attached to respondent's objection on the ground that petitioner
was prejudiced by the fact that those exhibits were not attached
to the notice of deficiency.6 Petitioner further moves to strike
that portion of respondent's objection in which respondent refers
to the issue that respondent seeks to place in dispute by way of
her pending Motion for Leave to File Amendment to Answer.
Upon due consideration of the foregoing matter, we fail to
see any meaningful prejudice to petitioner in respect of the
concerns expressed in its Motion to Strike. Consequently, and in
view of the action that we propose to take in respect of
5 The two exhibits in question are separate Forms 3233
(Report of Gift Tax Examination Changes) prepared by an Internal
Revenue Service examiner relating to a review of the previously
mentioned gift tax returns filed on behalf of decedent and Mr.
Rickman.
6 Although not particularly relevant to the jurisdictional
issue to be decided, we note that counsel for petitioner disputes
representations appearing in the Reports of Gift Tax Examination
Changes that the reports either were discussed with him or that
he agreed with the adjustments set forth therein.
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