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proposed adjustments in the 30-day letter. In this protest,
petitioner requested an appeals conference and further asserted
that (1) respondent had failed to account for petitioner's
deductible losses and business expenses, (2) petitioner was
married during 1992, and, therefore, the income from third-party
payers was community property income of which only 50 percent was
taxable to him, (3) respondent had failed to allow petitioner the
correct standard deduction as well as a dependency exemption for
his son, (4) respondent had failed to account for an overpayment
from petitioner's 1994 tax year that had already been applied
toward his proposed deficiency for 1992, and (5) the additions to
tax should not be imposed because petitioner's failure to file a
return and pay estimated taxes was due to reasonable cause. The
protest contained a detailed recitation of facts and legal
arguments to support petitioner's assertions; however, very
little relevant supporting documentation was submitted with the
protest. Specifically, petitioner submitted: (1) A Form 2848,
power of attorney; (2) the aforementioned Form 4868, request for
a filing extension for 1992; (3) his wife's Federal income tax
return for 1992 (filed March 15, 1994); (4) a profit and loss
statement that was prepared by the petitioner with regard to his
1992 contract work at Seton Medical Center;3 (5) two "Notices of
3 Petitioner also reported on this statement that his truck
was repossessed by G.M.A.C. during 1992, entitling him to a loss.
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