- 3 - to his original investment.2 As a result of the increase in petitioner's adjusted gross income, respondent also made a computational adjustment to petitioner's allowable casualty loss deduction. In the statutory notice of deficiency, respondent determined petitioner's Federal income tax liability for 1994 to be $10,238. After the statutory notice of deficiency was issued on February 25, 1997, petitioner communicated with respondent's Ogden Service Center by letter of February 27, 1997, and by telephone on April 1, 1997, to discuss the adjustments determined in the statutory notice. In a letter to petitioner dated April 9, 1997 (the letter), from a member of respondent's Problem Resolution Staff, which enclosed a report that purportedly supplemented the February 25, 1997, notice of deficiency, the letter explained to petitioner the reasons for the adjustments made in the statutory notice. It further informed petitioner that it was determined that he was entitled to an additional gambling loss in the amount of $126. In recalculating petitioner's 1994 Federal income tax liability, 2 Petitioner received annuity payments from the OPM Retirement Program in the total amount of $2,359 during 1994. Petitioner's original contributions to the OPM Retirement Program amounted to $2,511. At trial, respondent's counsel stated to the Court that respondent would be able to calculate the excludable portion of the annuity payments from petitioner's responses to her line of questioning with respect to this matter. We therefore direct respondent to take into account the excludable amount of the annuity payments in the Rule 155 computation.Page: Previous 1 2 3 4 5 6 7 Next
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