- 6 - 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 withPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011