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opportunity to respond to these issues before respondent issued
the notice of deficiency.
Petitioner also stated that when it was informed by
respondent that a notice of deficiency would be issued if
petitioner did not agree to an extension of the statutory period
for assessment, that it welcomed the notice as an opportunity to
resolve the issues. This statement is contrary to petitioner's
statement that the notice of deficiency was issued to harass
petitioner.
We are not persuaded by petitioner's arguments. We find
nothing in our review of the record to support petitioner's
claims of overreaching or abusive tactics by respondent's agents.
Rather, we find that respondent promptly conceded that
petitioner's deductions were allowable once petitioner provided
the information necessary to substantiate the disputed items.
Although petitioner attempts in its motion to articulate the
overreaching of respondent's agents, such statements are not
proof. See Rule 143(b); see also Niedringhaus v. Commissioner,
99 T.C. 202, 214 n.7 (1992); Viehweg v. Commissioner, 90 T.C.
1248, 1255 (1988).
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