Nina H. Pettyjohn - Page 5




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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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