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Security income, computational adjustments for self-employment
tax and the earned income credit, an allowance for additional
itemized deductions, and imposition of the accuracy-related
penalty under section 6662(a).
Petitioner filed her petition on June 24, 1993. Respondent
filed an answer on August 17, 1993.
On September 10, 1993, the same IRS Appeals Officer
considering petitioner's 1988 tax year mailed a letter to
petitioner's attorney suggesting a conference for settlement of
the case for 1989, without trial, or to submit additional
evidence to support petitioner's case. Petitioner did not
respond to this letter, nor was any additional documentation
provided.
On October 20, 1994, the Appeals Officer mailed another
letter to petitioner renewing the offer to discuss the issues for
both the 1988 and 1989 cases. The letter noted this Court's
opinion in Sharer v. Commissioner, T.C. Memo. 1994-453 (with
respect to petitioner's 1986 and 1987 tax years). Petitioner's
attorney responded to this letter on November 2, 1994, and
provided some information regarding the 1989 year. The record is
unclear, however, as to what information was actually sent to
respondent. On November 22, 1994, the Appeals Officer responded
to the November 2, 1994, letter from petitioner's attorney
acknowledging receipt of the information.
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