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Minervini, Appeals Officer. The memorandum indicated that
District Counsel's office had reviewed a proposed notice of
deficiency with respect to petitioners for their taxable year
1986. District Counsel's memorandum advised:
We discovered errors in your calculation of the
capital gains adjustments as set forth on exhibit A
attached to the notice. The capital gains adjustments
are based entirely upon an exhibit used in connection
with the criminal case at docket no. 90-CR-777-1.
Reliance on this document is necessary at this point
because all of the supporting documentation is grand
jury material and unavailable to the IRS until a rule
6(e) Order is obtained. Consequently, without the
supporting documentation, it is imperative that your
computation match the numbers contained on exhibit #3.
Accordingly, we have circled the numbers on your work
paper (copy attached) that we think are incorrect and
ask that you verify the accuracy of the numbers by
comparing them to exhibit #3.
Attached to the memorandum were workpapers that reflected
the capital gain totals that had been set forth in the 30-day
letter. District Counsel had made minor changes to the gains
determined in two corporate brokerage accounts--a $3 change for
"Black Bird Investments" and a $60 change for "Tornado
Resources". When these changes had been made, the totals for
those two entities, as well as the overall totals, exactly
matched those derived, for the year 1986, from exhibit 3, the
"Corporate Brokerage A/C's Gains & Losses 1985-86".
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