- 12 -
Supplies - $7,108.
Nevertheless, the letter concluded by stating that for 1986,
respondent was prepared to allow the previously disallowed
Schedule E Barrington Park partnership loss ($26,710) and the
gift tax basis in the shares of United Funds, Inc. ($21,365);
however, the letter emphasized that “without proper documentation
of the above Schedule C expenses, we will be unable to reconsider
that portion of our initial examination findings.”
On March 13, 1996, respondent’s Problem Resolution Office
sent Mr. Peterson a letter stating that “we haven’t heard from
you yet.”
After a response from Mr. Magness on March 20, 1996,
requesting, inter alia, additional time to provide the previously
requested information and documentation, respondent’s Problem
Resolution Office agreed to extend the time to April 22, 1996.
However, Mr. Magness was advised that if such information and
documentation were not received by that time, respondent would
allow only the Schedule E Barrington Park partnership loss and
the gift tax basis in the shares of United Funds, Inc., and no
allowance would be made for disallowed Schedule C expenses for
either 1985 or 1986.
The requested information and documentation was apparently
not received. Accordingly, on May 27, 1996, respondent abated
only $23,785.64 of the original $47,294 assessment of the income
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