Robert D. Grossman, Jr. - Page 135

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          calculating the 1985 deficiency that respondent determined in the           
          instant cases.                                                              
          2  Adjusted gross income is not shown on the indicated documents.           
               In 1989, Brown photocopied some Sley Corporations records.             
          She turned those records over to respondent’s agent in August               
          1989, and provided other information to that agent.                         
               On June 14, 1990, respondent mailed to petitioner and Betsy            
          a notice of deficiency for 1986.  On April 4, 1991, respondent              
          mailed to petitioner and Betsy a notice of deficiency for 1983,             
          1984, 1985, and 1987.  Also on April 4, 1991, respondent mailed             
          to petitioner a notice of deficiency for 1988.  Petitioner filed            
          petitions in response to these three notices of deficiency,                 
          giving rise to the instant cases.                                           
               The notice of deficiency for 1986 was mailed more than 3               
          years after the 1986 tax return was filed, but within the period            
          agreed upon in the parties’ timely extension agreement.  Sec.               
          6501(c)(4).  The notice of deficiency for 1983, 1984, 1985, and             
          1987 was mailed more than 3 years after the 1983, 1984, and 1985            
          tax returns were filed, but within 3 years after the 1987 tax               
          return was filed.  The notice of deficiency for 1988 was mailed             
          within 3 years after the 1988 tax return was filed.                         
                             Interest Expense for 1987.                               
               At sometime before 1987, Betsy borrowed money from Markette,           
          a portion of which was to be repaid in 1987.  Betsy wrote check             






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