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that, for 1992 and 1993, those accompanying pages exist and were
received by petitioner. Those pages identify as rental income
the type of income that petitioner failed to report, state the
addresses of the particular rental properties in question,
identify an amount with respect to each such property, and
explain that respondent determined those amounts from available
information, including information provided by the payers of that
rental income and third-party recordkeepers. We assume that
similar information accompanied the notices for the other years
in question, which petitioner failed to attach to the petition.
Indeed, among petitioner’s requests for admissions, petitioner
requests that respondent: “Admit or deny that the ‘rental
income’ stated in all Notices of Deficiency is an estimate.”
(Emphasis added.) Although not free from ambiguity, that request
supports our assumption that petitioner received the same type of
information for all of the years in issue. In any event, after
the petition was filed, and before this case came on for trial,
respondent’s counsel provided to petitioner a summary for each
year in issue of the rental amounts associated with each parcel
of real estate of which respondent was aware.
We think that the notices of deficiency, together with the
petition and the summary provided to petitioner by respondent’s
counsel, provide the minimal evidentiary foundation required by
Weimerskirch v. Commissioner, 596 F.2d 358 (9th Cir. 1979). We
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