- 5 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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