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respondent’s Atlanta Service Center, together with a personal
check in the amount of $1,500, agreeing with the examination
report insofar as the disallowance of the deduction for gifts to
family members was concerned. Petitioner’s letter and check were
received by the Service Center on August 22, 1996. However, the
letter was apparently not forwarded to the examining agent.
Consequently, on September 19, 1996, respondent sent petitioner a
notice of deficiency which was substantively identical to the
examination report.
On September 30, 1996, petitioner timely filed an imperfect
petition for redetermination (assigned docket No. 21486-96) with
this Court. See sec. 6213(a); Rule 34. On December 2, 1996,
petitioner perfected her petition by filing a proper amended
petition. Upon the filing of respondent’s answer on March 28,
1997, the case was at issue. See Rule 38.
2. The Stipulated Decision
By letter dated June 10, 1997, respondent’s Appeals Office
in Atlanta, Georgia, mailed a proposed stipulated decision to
petitioner. The proposed stipulated decision reflected a
deficiency in petitioner’s income tax for 1993 of $2,115 based
solely on the disallowance of the deduction for gifts to family
members.6
6 Respondent conceded all other substantive adjustments
made in the Sept. 19, 1996, notice of deficiency.
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