- 6 - adjustments totaling $83,845. Consistent with the determinations in the notice of deficiency for 1986 and 1987, respondent determined that, for 1988, petitioner was required, under California's community property law, to include in her income one-half of the net income, or $40,415, of Sharer Accountancy, her late husband's accounting proprietorship. Other adjustments totaled $25,205, which included automobile allowances paid to petitioner by Gold Country, unaccounted and unexplained deposits to petitioner's bank accounts, and personal expenses of petitioner paid by a third party. Respondent also determined that $20,000 petitioner received from a law firm during 1988, as well as a State income tax refund of $1,312, constituted gross income. All of these adjustments, except for the $40,415 from Sharer Accountancy, were based upon bank records and information provided to respondent by payors. Petitioner filed her petition on October 9, 1992, contesting the deficiency notice for 1988. On December 10, 1992, respondent filed an answer. On September 27, 1993, an Appeals Officer of respondent mailed a letter to petitioner's attorney setting out the issues and inviting the attorney to submit evidence in support of petitioner's case, noting that the case was calendared for trial on January 24, 1994. Respondent also suggested that petitioner sign a Stipulation to be Bound by the finding of the Court for tax years 1986 and 1987 with respect to the issue ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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