Carolyn S. Eifert, A/K/A Sue Armstrong - Page 13

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          form showed that a debt in the amount of $251,203.73 was canceled           
          in 1993.  That form also identified: (1) The creditor as the FDIC           
          (as receiver for Moncor Bank); (2) the creditor's EIN as 85-                
          0096874; (3) the debtor as Eifert's Fashions & Shoes/Carolyn Sue            
          Eifert: and (4) the account number as 2495-00018627-1.                      
               By letter dated August 16, 1996, petitioner's counsel sent             
          Mr. Romero a copy of the FDIC communication dated August 9, 1996.           
               By letter dated August 26, 1996, Mr. Romero sent                       
          petitioner's counsel a form of decision for the latter's review             
          and signature.  The form of decision provided that petitioner was           
          not liable for any deficiency in income tax or additions to tax             
          for the taxable year 1993.                                                  
               Upon receipt, petitioner's counsel promptly signed the form            
          of decision and, by letter dated August 29, 1996, returned it to            
          Mr. Romero.                                                                 
               A supervisor in respondent's District Counsel office in                
          Phoenix, Arizona, signed the form of decision on October 8, 1996.           
          The form of decision was then mailed to the Court in Washington,            
          D.C.                                                                        
               On October 16, 1996, the Court entered a decision in this              
          case (the decision) utilizing the form of decision furnished by             
          the parties.                                                                









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