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other debts we are required to collect”. Petitioner received a
$39,229.76 refund shortly thereafter (the refund for 1996).2
By letter dated June 7, 2002, respondent’s Austin Service
Center responded to an unspecified inquiry from petitioner
regarding his 1999 taxable year. The letter states in part:
“You don’t need to do anything further now on this matter. * * *
If you receive or have received additional notices about this
account, please disregard them.”
On September 18, 2002, the Court issued its Standing
Pretrial Order and Notice, setting the case for trial at the
trial session of the Court commencing on February 24, 2003, in
Dallas, Texas. Subsequent consultations between the parties led
to the stipulation of facts and stipulation of settled issues
referenced above.
Discussion
I. Deficiencies
A. Effect of Respondent’s Prior Actions
Although petitioner assigns error to respondent’s
determinations of deficiencies in tax for each of the audit
years, petitioner’s only pertinent averments are that respondent
allowed no business expenses in computing petitioner’s income and
did not acknowledge payments made by petitioner. Petitioner does
2 That amount equals the sum of the abated assessments for
1996 ($35,694.86) and interest thereon ($3,534.90). There is no
explanation of why this refund was made.
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