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Entry of Decision and a proposed Decision (the Rule 155
computation).
At this time, petitioners hired Donald Bailey, a certified
public accountant, to assist them. While working on the Rule 155
computation, Mr. Bailey discovered that respondent’s
determination failed to include as Schedule A, Itemized
Deductions, property taxes formerly claimed by petitioners on
their Schedules F, Profit or Loss from Farming. Once informed of
the matter, respondent adjusted petitioners’ liabilities
accordingly.
After several sets of revisions, on February 28, 2001,
petitioners sent to respondent the Rule 155 computation and
indicated in an accompanying letter that petitioners did not
agree to the interest amounts. On March 19, 2001, respondent
submitted the Rule 155 computation to this Court,2 and, on April
13, 2001, this Court entered a decision, upholding the
deficiencies.
On July 31, 2001, respondent assessed the deficiencies and
assessed interest in the amounts of $4,557.32 for 1992, $4,775.59
for 1993, and $4,144.29 for 1994. Petitioners filed Form 843,
2On Mar. 23, 2001, this Court issued a Notice of Filing of
Computation under Rule 155, advising petitioners to file their
notice of objection by Apr. 13, 2001. Petitioners filed
Petitioners’ Computation for Entry of Decision and Notice of
Objection to Respondent’s Proposal on Apr. 6, 2001, objecting
solely to the amount of interest shown as due.
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