- 8 -
merely stated that the funds had been disbursed and
declined to comment further;
(6) When agents of the Internal Revenue Service
attempted to contact your solicitors, Maxwell, Glasner
& Co., with respect to their involvement in the A.T.O.
Marketing Limited settlement, they refused to provide
information unless you agreed to waive the attorney-
client privilege, which you have refused to do; and
(7) Since you directed the disposition of the
settlement funds, and were the last person in
possession, custody and control of the Bank Draft
payable to the Swiss Bank Corporation on May 7, 1987;
since you have declined to further document is [sic]
disposition, which disposition cannot be documented
beyond your receipt; and since the entity for whose
benefit it was allegedly applied denies receipt or any
benefit from the Bank Draft, it is determined that the
entire amount of the Bank Draft is income to you for
the taxable year 1987.
Accordingly, your taxable income is increased in
the amount of $965,425.00 for the taxable year ending
December 31, 1987. See the schedule below for this
computation.
Proceeds from settlement 575,000 pounds sterling
Exchange rate 1.6790 dollars to pounds
Proceeds from settlement
in U.S. dollars $965,425
In the notice of deficiency, respondent also stated (and
petitioner does not dispute) that petitioner reported $29,577 in
income for 1987.
Discussion
Petitioner contends that this Court lacks jurisdiction to
decide this case because respondent's notice of deficiency is
invalid. Petitioner contends that (a) respondent failed to make
the required determination of an actual deficiency, (b) the
notice was prepared with gross ineptitude, and (c) respondent is
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