Girish and Nalini G. Patel - Page 2

                                          2                                           
               At the time their petition was filed, petitioners resided in           
          Houston, Texas.  References to petitioner are to Girish Patel.              
               The Internal Revenue Service, Austin, Texas, Service Center            
          (IRS) mailed a letter (30-day letter) to petitioners on September           
          25, 1996, proposing changes in their 1994 income tax return.  On            
          the schedule attached to the 30-day letter, respondent increased            
          taxable income by $7,161, resulting in an increase of $1,072 in             
          petitioners’ 1994 tax liability.  The adjustments were (1) $7,146           
          of additional interest income from two accounts at NationsBank of           
          Texas, and (2) $15 of additional wage income.  Respondent’s                 
          adjustments were based upon a comparing of the amounts reported             
          on petitioners’ Federal income tax return for wages and interest            
          with Forms W-2 and Forms 1099 received from the payors.  The 30-            
          day letter stated:                                                          
               If you don’t agree with the proposed changes on page 2:                
                    - Check box B on the last page of this notice,                    
                    - Enclose a signed statement explaining why you                   
               disagree,                                                              
                    - Include any supporting documents you wish us to                 
               consider, and                                                          
                    - Use the envelope enclosed to return the last page of            
               this notice with your statement and documents.  Please                 
               include a telephone number, including an area code, and the            
               best time to call you.                                                 
               The letter stated that if the IRS did not receive a response           
          within the 30-day period, a notice of deficiency would be issued.           
          Petitioners would be able to contest the notice of deficiency in            
          Court.  Petitioners did not respond to the 30-day letter, nor did           
          they request an Appeals Office conference.                                  





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