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the Bronsons’ tax return for the taxable year in issue. Ms.
DiTommaso does not specifically recall preparing the return in
question. However, the procedure which she would have followed
at the time was to use the Schedule K-1 provided and to rely upon
the information on the schedule because nothing looked “odd or
out of the ordinary”.
Following the entry of the decision concerning the
partnership, discussed above, respondent adjusted the Bronsons’
return by disallowing their claimed share of the partnership
loss, $17,369, and making a computational adjustment to their
itemized deductions. In the statutory notice of deficiency which
provides the basis for our jurisdiction in this case, respondent
determined that the Bronsons are liable for additions to tax
under section 6653(a)(1) and (2) in the respective amounts of
$186 and 50 percent of the interest due on a $3,712 deficiency.
Prior to issuing the notice of deficiency, respondent did not
make inquiries of the Bronsons concerning the proposed
adjustments, nor did respondent provide them with an opportunity
for an administrative appeal.
The Gordon-Wylies
Petitioner Donald K. Gordon-Wylie was a sales account
manager at Digital Equipment Corporation during 1983. He
possesses an associate’s degree and has no academic background in
accounting, finance, tax, or economics. Petitioner Frances T.
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