Mary Lee Sharer - Page 8

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          provided some documentation to respondent.  The record does not                    
          indicate what information was enclosed with this letter.  By                       
          letter dated January 10, 1995, petitioner's attorney provided                      
          further documentation to respondent.  Again, the record does not                   
          indicate what information was provided in this letter.  This                       
          letter, however, indicated petitioner's inability to locate                        
          documentation justifying the "auto expense", one of the                            
          adjustments in the notice of deficiency that respondent                            
          determined was taxable income.                                                     
                On March 3, 1995, respondent sent a letter to petitioner's                   
          attorney summarizing the issues in the 1988 and 1989 cases.  In                    
          the letter, respondent conceded the 1988 $40,415 community                         
          property income adjustment as a result of the opinion in Sharer                    
          v. Commissioner, supra.  Respondent also conceded part of the                      
          1988 $25,205 adjustment for additional earned income but                           
          requested additional documentation as to the other parts of this                   
          adjustment and the $20,000 adjustment for a payment received by                    
          petitioner from a law firm during 1988.  Petitioner claimed that                   
          the $20,000 payment was a personal injury settlement, which was                    
          not taxable under section 104(a)(2).  Respondent requested                         
          further information on this item because some of respondent's                      
          documentation indicated that petitioner's claim included taxable                   
          as well as nontaxable elements.  Finally, respondent conceded the                  
          adjustment for the State income refund, and also allowed                           





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