Patricia Williams, a.k.a. Patricia Richardson, a.k.a. Tish Martinson - Page 7

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          Notice of Deficiency                                                         
               On February 15, 1996, respondent issued a notice of deficiency          
          to petitioner. The notice stated that upon conducting a bank                 
          deposit analysis of petitioner's City National Bank accounts, the            
          Commissioner determined that petitioner failed to report taxable             
          income of $167,693 in 1987, $85,204 in 1988, and $259,957 in 1989.           
          On May 10, 1996, petitioner filed a petition with this Court,                
          denying that she had any unreported taxable income during the years          
          in issue.  In the answer filed on June 24, 1996, respondent                  
          asserted that some of the bank deposit sources were verified.                
          Settlement Negotiations                                                      
               In late July 1996, Mr. Guterman received a letter from Appeals          
          Officer Steve Millang requesting a settlement conference for August          
          12, 1996.  The meeting was never scheduled due to the fact that              
          Mr. Guterman was awaiting the result of a bank deposit analysis              
          conducted by Steve Slatkin, an expert retained by Mr. Guterman.              
          Additionally, Mr. Guterman was awaiting  the  production  of                 
          additional bank deposit documents in the IRS's possession. Appeals           
          Officer Millang forwarded the additional documents to Mr. Guterman.          
               On or about September 24, 1996, Mr. Guterman wrote District             
          Counsel Linas Udrys and requested the latter to obtain additional            
          bank deposit information from the CID.  On November 5, 1996,                 
          Appeals Officer Millang wrote Mr. Guterman advising that the CID             







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