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than result in respondent's considering the matter, in the words
of respondent's examining revenue agent, as "basically a
protestor case".
Set against the background of this correspondence, the years
here in dispute were assigned to a revenue agent for examination
sometime in the fall of 1993. The revenue agent attempted
unsuccessfully to contact petitioner at petitioner's place of
employment1 on December 2, 1993. The examination was closed on
January 10, 1994, and the notice of deficiency upon which this
case is based was issued on March 23, 1994.
Because petitioner did not file Federal income tax returns
for the years in issue, or keep any records reflecting the amount
of income he earned and expenses he incurred during those years,
and because there was little meaningful communication between
petitioner and respondent during the examination stage,
respondent reconstructed petitioner's income for each year
relying in part upon information received from third-parties, and
in part upon information published by the United States Bureau of
Labor Statistics (BLS). The reconstruction of petitioner's
income for each year as set forth in the notice of deficiency is
summarized in the following table:
1989 1990 1991 1992
1The words "employment", "employer", etc. are used for
convenience throughout this opinion. The use of such words is
not meant to imply the existence of an employer-employee
relationship.
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