Phuong K. Nguyen - Page 6




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                    After reviewing the information we received on                    
               7/12/1999, we reconsidered your 1998 federal income tax                
               liability and accepted your 1998 return as filed or as                 
               adjusted previously.                                                   
                    Please disregard the notice of deficiency we sent                 
               you on 7/16/1999.  You will not need to file a petition                
               with the United States Tax Court.                                      
                    If you have any questions, you may write or call                  
               the tax examiner whose name, telephone number, and                     
               contact hours appear at the top right corner of this                   
               letter.                                                                
               The no-change letter was issued by the chief of one of the             
          customer service divisions in respondent’s Atlanta Service                  
          Center.                                                                     
               Notwithstanding the no-change letter, petitioner retained              
          Bruce E. Gardner (Mr. Gardner) to represent her.  Mr. Gardner is            
          an attorney who is admitted to practice before this Court, and he           
          is petitioner’s counsel of record in the present proceeding.                
          Petitioner met with Mr. Gardner on August 28, 1999.                         
               Consistent with the no-change letter, respondent mailed a              
          check to petitioner on September 13, 1999.  The amount of the               
          check, $2,808.67, represented the refund claimed by petitioner on           
          her 1998 return, i.e., $2,725, plus $83.67 of interest.                     
               On October 14, 1999, Mr. Gardner hand delivered a petition             
          to the Court, thereby commencing a case on petitioner’s behalf.             
          See sec. 6213(a).                                                           
               On December 13, 1999, respondent filed a motion to extend by           
          60 days the time within which to file an answer to the petition.            






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