Holly Ruocco - Page 3

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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                         
          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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