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On February 24, 1989, petitioners' 1985 return was assigned
to Office Auditor Barrow. On that date, Office Auditor Barrow
sent petitioners a Form 4564 with respect to their 1985 return.
A second Form 4564 was sent to petitioners on April 4, 1989.
Respondent sent Reports of Individual Income Tax Examination
Changes (Form 4549) to petitioners, which reflected proposed
adjustments.4 The proposed adjustments to petitioners' Schedule
C deductions for 1985, 1986, and 1987 were in the amounts of
$2,930, $10,379, and $15,363, respectively.5
In a letter dated May 19, 1989, respondent requested that
petitioners respond to the Forms 4549 that had been sent to them
and informed petitioners that they could have their case
transferred to respondent's Appeals Office. The letter also
stated that respondent would issue a notice of deficiency if
petitioners failed to respond within 15 days.
Petitioners, through their daughter-in-law, requested that
their case be sent to Appeals. On July 21, 1989, petitioners'
case was transferred to respondent's Appeals Office in
Jacksonville, Florida. On July 25, 1989, Appeals Officer Sandra
G. Holder sent petitioners a letter advising them that the case
had been referred to her and that she would call or write to
4Respondent's Forms 4549 for petitioners' 1986 and 1987
years are both dated Jan. 18, 1989; her report for petitioners'
1985 year is dated May 1, 1989.
5A listing of each of Office Auditor Barrow's adjustments
for 1985, 1986, and 1987 is contained in the appendix.
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