- 3 -
C, we will provide sufficient documentation to essentially permit
you to accept my 1993 form 1040, as filed."
In a letter dated August 21, 1996, petitioner submitted to
respondent a second set of documents to substantiate her claimed
1993 deductions for what she now referred to as an 8-month year.
Petitioner advised respondent that "most of [her] original
documents have been displaced or destroyed." She asked
respondent to "extrapolate" and make estimates. She stated that
she only had 2 months of electric and gas invoices and
substantiation of these expenses would be forthcoming upon
receipt of copies of statements from the respective utility
companies.
In a letter dated November 25, 1996, petitioner stated that
she enclosed a copy of a Form 872, Consent to Extend the Time to
Assess Tax, so that she could obtain additional information.
In a letter dated January 6, 1997, the District Director
informed petitioner that the period of time in which the Service
might assess tax for the tax period ended December 31, 1993, had
been extended to April 15, 1998.
On April 24, 1997, respondent mailed a notice of deficiency
to petitioner. In the notice, respondent determined a deficiency
in the amount of $5,495 in petitioner's 1993 Federal income tax.
The deficiency was based on disallowance of itemized deductions,
the cost of goods sold, and Schedule C expenses. The notice of
deficiency stated that the miscellaneous deduction was disallowed
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