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$100,195 in deductions claimed on the Canyon State Chiropractic
return was disallowed.
The notice of deficiency for 1997 was addressed only to
petitioner. It explained the primary adjustment as follows:
1A. SCH C–CANYON STATE
It is determined that you received income or other
distributions from your chiropractic business in the
amount of $375,400 for the taxable period ended
December 31, 1997. This amount is taxable to you
because you have not established that the income is
excluded from gross receipts under the provisions of
the Internal Revenue Code. In the absence of adequate
records, this income has been determined on the basis
of available information and by analyzing bank
deposits.
The addition to tax was based on petitioner’s failure to file a
tax return for 1997.
At the time that she filed the petition, petitioner resided
in Salem, New Hampshire. In the petition, petitioner claimed
that the determinations in the notices of deficiency were based
on “Error in attributing income to the petitioner that she did
not receive.” Petitioner also alleged that she “did not receive
any of the income alleged in the Notices of Deficiency from a
taxable source.” Petitioner designated Phoenix, Arizona, as the
place of trial of this case.
By notice served August 24, 2001, the case was set for trial
in Phoenix on January 28, 2002. Attached to the notice of trial
was a Standing Pre-Trial Order that provided, among other things:
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