Mary Lee Sharer - Page 6

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          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 of                     





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