Marion Goldin - Page 6

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                    This consequently causes a reduction in the                       
               interest billing of approximately $5,904.                              
               These findings create concern about the accuracy of the                
               1982 and 1981 tax billings.  Would you please recompute                
               these two years considering the impact of Income                       
               Averaging.                                                             
               Enclosed are the following supporting schedules:                       
                    1.   Review of Tax Year 1983                                      
                    2.   Schedule G Income Averaging - 1983 recomputed                
                    3.   Copy of IRS detailed interest calculation                    
                         Adjusted for affect (sic) of tax reduction.                  
                    4.   Copy of Form 1040 Page 1 & 2 as originally                   
                         filed for years 1983, 1982, 1981                             
                    5.   Review of tax year 1982, reflecting                          
                         disallowance of Robotics and Schedule A                      
                         Business Deductions                                          
                    There appears to be some confusion about whether                  
               or not the Schedule A Business deduction disallowance                  
               was included in the tax deficiency billed.  It was                     
               included as proven by Schedule 5.                                      
                    Please review the data enclosed and adjust your                   
               billings accordingly.  If I can be of any assistance in                
               concluding this matter please do not hesitate to                       
               contact me.  Please consider the taxpayer’s position,                  
               Mrs. Goldin has been widowed for the past several years                
               and extremely flustrated (sic) by this entire mess.                    
          C.   Petitioner’s Request for Relief From Joint Liability for               
               1983-84                                                                
               On March 15, 1999, petitioner filed a Form 8857, Request for           
          Innocent Spouse Relief, for tax years 1981-84.  In the Form 8857,           
          petitioner requested relief from joint liability under section              
          6015.  She included a request for refund of tax paid for 1983-84            
          relating to Robotics.                                                       
               By letter dated December 3, 1999, respondent’s District                
          Director told petitioner that she was entitled to relief under              





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