Garry F. Bettencourt and Phyllis C. Bettencourt - Page 3




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          with the Superior Court on August 30, 1991, "Child Support Paid             
          by Garry Bettencourt" summaries for the year 1993, and wage stubs           
          showing amounts paid to petitioner by Medallion Mortgage Company            
          during 1993.                                                                
               On May 18, 1995, respondent sent petitioners a 30-day letter           
          proposing to disallow the claimed alimony deduction.                        
               In response to the 30-day letter, on June 3, 1995,                     
          petitioners' counsel, Mr. Read, mailed to respondent a five page            
          letter protesting respondent's proposed income tax examination              
          changes.  He forwarded with his letter a power of attorney, Form            
          2848, and requested that petitioners' return be accepted as                 
          filed.  In the event that respondent would not accept the return            
          as filed, Mr. Read requested that his letter be treated as a                
          formal protest and that the matter be referred to the Appeals               
          Office for hearing.  By letter dated June 14, 1995, Mr. Read sent           
          to respondent an original Form 2848, signed by petitioners.                 
               On June 27, 1995, respondent sent Mr. Read a letter                    
          proposing the same adjustments to petitioners' 1993 return as               
          were proposed in the May 18, 1995, 30-day letter.                           
               During the summer months of 1995, correspondence was                   
          exchanged between Mr. Read and respondent through which                     
          respondent sought additional information about the alimony issue.           
               A statutory notice of deficiency for 1993 was mailed to                
          petitioners on February 7, 1996.  Petitioners filed their                   
          petition in docket No. 7950-96 with the Court on April 26, 1996,            
          and respondent filed an answer on May 21, 1996; the case was then           
          referred to respondent's Appeals Office.                                    

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