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because of anthrax contamination in the U.S. Postal Service,4 and
the petitions did not reach the Tax Court until December 5, 2001.
The Tax Court served the petitions on respondent on December 6,
2001. Before receiving service of the petitions, respondent
assessed the deficiencies and penalties determined in the notices
of deficiency and notified petitioners and the petitioner trusts
of the assessments. After receiving service of the petitions,
respondent promptly abated most of the assessments.5 Letters
dated September 16, 2002, were sent to petitioners and the
petitioner trusts notifying them of the abatements.
The parties have stipulated that the petitioner trusts are
to be disregarded for Federal income tax purposes and that the
income reported on the petitioner trusts’ returns is income of
petitioners and should have been reported on their individual
returns.6
Petitioners concede that they should have reported
additional gross income of $56,272 and $72,587 in their returns
4 See, e.g., Gibson v. Commissioner, T.C. Memo. 2002-218.
5 While all of the assessments of the deficiencies against
petitioners for 1995, 1996, and 1997 were abated, respondent
failed to abate $1.09 of the assessment with respect to The
Connell Business Co. for 1997.
6 As a result, respondent has conceded the deficiencies
determined with respect to the petitioner trusts.
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