Don H. Wisden - Page 4

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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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