Laurel Ann Curtis - Page 6




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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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