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the notice of deficiency be appended to the petition and that
there shall be included so much of any statement accompanying the
notice as is material to the issues raised by the assignments of
error. Petitioner received four notices of deficiency, and she
attached to the petition only the first page of each. Those
pages contain no explanation of the adjustments giving rise to
respondent’s determinations of deficiencies. Petitioner’s
testimony and portions of her brief filed June 20, 1996
(petitioner’s brief), make it clear that there was more than one
page to each of the notices of deficiency received by her.
Indeed, attached to her brief is an “Exhibit A” (Exhibit A),
which states that it is an explanation of adjustments for 1992
and 1993. Petitioner offers Exhibit A as a portion of the
deficiency notice received by her for 1992 and 1993 that,
according to her contention, contains a mathematical error.
Petitioner has violated our Rules by not attaching to her
petition the portions of respondent’s notices that explain
respondent’s adjustments.
We have deduced, however, from Exhibit A and from
petitioner’s testimony and briefs that respondent’s adjustments
leading to the deficiencies in question result from respondent’s
claim that petitioner failed to report certain rental income from
real estate in each of the years in issue. Exhibit A states:
It is determined that you received gross income from
rental income as shown above. The gross income amounts
have been determined according to the information
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