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Moreover, respondent investigated petitioner’s denial of
having gambled at Gulf Greyhound Park at the first available
opportunity, and the results of respondent’s investigation were
sufficient to convince respondent to concede the case. Twice,
respondent made an offer of full concession to petitioner.
Twice, petitioner refused. The Court understands petitioner’s
frustration in having to endure the investigation and proceedings
and expend effort and resources to resolve it. However,
respondent did his part to clear up the matter. Although
respondent ultimately determined that the evidence was
insufficient to establish that petitioner received the gambling
income at issue, respondent is allowed reasonable time to
receive, analyze, and act upon documentation that proves
petitioner’s contentions before he is obligated to concede the
case. Gealer v. Commissioner, T.C. Memo. 2001-180. The Court
also notes that petitioner ignored the notification originally
sent to him by respondent prior to the issuance of the notice of
deficiency. Had petitioner responded earlier, the entire matter
could have been disposed of without the issuance of a notice of
deficiency and subsequent court proceeding. See Corkrey v.
Commissioner, 115 T.C. 366, 375 (2000).
Respondent’s actions in this case fall within the boundaries
of what is reasonable. Respondent has shown that his position
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