Roger L. and Patricia A. Lavallee - Page 4

                                                - 4 -                                                 
                  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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