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items in the ledger appeared to be nondeductible and/or
personal in nature. Petitioner was reluctant to provide any
information beyond what was contained in the ledger on the
ground that, since the items appeared in a ledger, they were
necessarily correct and further verification should be
unnecessary. Petitioners would not sign a Form 872 to extend
the statute of limitations, and the case was forwarded for the
issuance of a statutory notice of deficiency.
The notice of deficiency was mailed to petitioners on
December 12, 1996. The petition, consisting of seventy-seven
(77) paragraphs, most of which alleged "evidentiary facts",
was filed on March 7, 1997. Respondent's answer was filed on
March 31, 1997.
By letter dated June 20, 1997, to petitioners' attorney,
David P. Leeper, respondent's appeals officer informed Mr.
Leeper as follows:
Dear Mr. Leeper:
I have reviewed the examiner's workpapers that
were prepared in connection with the examination of
the Millers' tax returns for 1993. Based on these
workpapers, many of the expenses disallowed were for
lack of substantiation by the taxpayer.
The following information is need [sic] to help
resolve these issues at our scheduled appeals
conference:
1. A list of the recipients of the
various statuettes deducted as advertising
expense. This list should include the
location and approximate dates the items
were placed.
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