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resolved5 between the taxpayer and the Internal Revenue Service
Appeals Office, the computation of the deficiencies for those
years permitted the use of income averaging based on the amounts
of taxable income for the base years reflected by petitioner.
The 1976 and 1977 Federal income tax returns are not
available. Petitioner is unable to locate copies of those
returns, and respondent asserts that the original 1976 and 1977
returns have been destroyed. In an affidavit, petitioner asserts
that the amounts reflected for 1976 and 1977 on the Schedules G
attached to the 1978 and 1979 returns were correct. Accordingly,
petitioner asserts that taxable income was correctly reported on
the 1976 and 1977 Federal income tax returns. Transcripts of
account reflect the filing of the 1976 and 1977 Federal income
tax returns and further reflect amounts of adjusted gross
income.6
Petitioner further asserts that there were no investments in
partnerships and corresponding claims for distributive share of
losses in 1976 and 1977, which items were the subject of
adjustments for the years 1978 through 1982. Respondent does not
have any information or evidence that the amounts reflected as
5 The matter was settled administratively; thus, no
petition was filed in response to the 1978 and 1979 notices of
deficiency.
6 The transcript reflects the amounts of $863 and $1,304
for 1976 and 1977. While not clear from this document, the
parties have explained these amounts to represent adjusted gross
income.
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