- 5 - 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 informationPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011