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is nothing in the record to suggest why respondent could not have
contacted the FDIC in order to determine the basis on which the
Forms 1099-G were issued given the dubious nature of such forms.
Further, respondent issued the notice of deficiency after
only one attempt to contact petitioner. We again take note of
the fact that the notice determined a million dollar adjustment
to petitioner's income. As a consequence of this million dollar
adjustment, the notice determined a deficiency in petitioner's
income tax in the amount of $377,365, and additions to tax under
sections 6651(a) and 6654(a) in the amounts of $94,341.25 and
$15,809.68, respectively. The notice also advised petitioner
that she was liable for interest (calculated through December 20,
1995) in the amount of $74,934. Thus, according to the notice,
the total amount due from petitioner (calculated through December
20, 1995) was $562,450. Given a liability of this magnitude, and
in view of the dubious nature of the Forms 1099-G, we question
whether respondent should have issued the notice of deficiency
after making only one attempt to contact petitioner.
Indeed, we take note of the fact that respondent originally
proposed the liability of $562,450 in the 30-day letter that was
sent to petitioner in November 1995. Again, given the magnitude
of such liability, and in view of the dubious nature of the Forms
1099-G, we question whether respondent should have even proposed
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