Dennis P. and Diana C. Raquet - Page 3

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          to the correct deficiency amount for the 1982 tax year because              
          the error in the deficiency was evident from the other informa-             
          tion set forth in the notice of deficiency.  The issues for                 
          decision are:                                                               
               (1)  Whether respondent bears the burden of proof when                 
          respondent increases a deficiency in her Amendment to Answer when           
          the increase in deficiency was due to a clerical error in the               
          notice of deficiency.  We hold that respondent only bears the               
          burden of establishing the clerical or mathematical error.                  
          Petitioner retains the burden with regard to respondent's sub-              
          stantive determinations.                                                    
               (2)  Whether respondent's Motion to Dismiss for Lack of                
          Prosecution should be granted.  We hold that it should.                     
                                  FINDINGS OF FACT                                    
               At the time the petition was filed, petitioners resided in             
          Los Gatos, California.  By two statutory notices of deficiency,             
          each dated July 11, 1988, respondent determined deficiencies,               
          additions to tax, and increased interest in petitioners' Federal            
          income taxes for the tax years 1979, 1980, 1981, and 1982.  The             
          adjustments determined in the notices of deficiency were with               
          regard to petitioners' participation in two tax shelter projects:           
          (1) Encore Leasing Corp. and (2) Kelsey/Soda Lake Mining.                   
               In the notice of deficiency for the taxable year 1982 (the             
          notice of deficiency), respondent asserted adjustments of                   
          $93,930.  Thus, respondent increased petitioners' taxable income            




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