Laurel Ann Curtis - Page 5

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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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