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figured the deficiencies set forth, and (3) that any petition to
the Tax Court be accompanied by “a copy of this letter and a copy
of all statements and schedules you received with this letter”.
The Posttrial Memorandum
Petitioner has attached as Exhibit A to the posttrial
memorandum two pages that accompanied the notice of deficiency
for 1992 and 1993. Those pages set forth respondent’s
adjustments, increasing petitioner’s rental income, “Per Audit”,
in the amounts of $98,180 and $85,620, for 1992 and 1993,
respectively. There is a schedule setting forth the addresses of
the rental properties in question, along with amounts of rental
income, rental expenses, and depreciation, for each. The
following explanation follows immediately upon the statement of
adjustments:
It is determined that you received gross income from
rental income as shown above. The gross income amounts
have been determined according to the information
available, including information provided by the payers
of rental income and/or third party recordkeepers.
Respondent’s Counsel’s Communication to Petitioner
Brenda M. Fitzgerald is respondent’s counsel in this case.
By letter dated February 7, 1996, Ms. Fitzgerald answered
petitioner’s request that respondent provide her with specific
sources and amounts from which respondent computed petitioner’s
deficiencies for each year. Ms. Fitzgerald enclosed with her
letter a summary for each year of the figures associated with
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