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Petitioner filed an amended petition in which she alleged
that she had filed a tax return for 1999, that all of
respondent’s determinations were in error, and that she was due a
refund of $1,609.
By letter, an Appeals officer requested additional
information about petitioner’s dependency exemptions, sales of
stocks and bonds, and receipt of distributions. Petitioner
provided additional documents to respondent, but the case
remained unresolved.
This case was subsequently set for trial at a San Francisco
trial session but was continued upon petitioner’s oral motion.
Respondent asked petitioner to provide information with
respect to certain income items that did not appear to be
reported on petitioner’s return, information verifying
petitioner’s basis in securities, and information verifying
certain rental expenses she had deducted. Respondent also sent
petitioner a letter summarizing the information that had been
verified as of that time and requesting additional information.
Petitioner failed to provide the information.
Respondent’s counsel informed petitioner by letter that,
pursuant to Rule 91, the parties are required to submit a
stipulation of facts to the Court. Respondent’s counsel proposed
a meeting to complete the stipulation of facts and advised
petitioner to provide documentation if she intended to claim
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Last modified: May 25, 2011