- 8 - 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 allowedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011