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understanding of that documentation, due to additional
explanations with regard to the documentation provided by the
estate’s counsel and to additional information and explanation
with regard thereto provided to respondent through contacts
respondent’s employees initiated with employees of the Nevada
casinos.
On the record before us, we believe it would be
inappropriate for us to conclude herein that the documentation
that was provided by or on behalf of decedent to respondent at
the examination office and Appeals Office was so obvious and
understandable that respondent should have conceded the claimed
gambling losses in full without issuing a notice of deficiency
and without expecting the estate to provide the additional
explanation and information with regard thereto that eventually
was used by respondent to properly understand and determine the
amount of decedent’s gambling losses.
Further, we regard it as reasonable for respondent to expect
decedent’s representative, during the Appeals Office
consideration of decedent’s protest, to produce specific
documentation, as contemplated by Rev. Proc. 77-29, 1977-2 C.B.
538, and to provide credible explanation thereof that adequately
verifies decedent’s gambling losses.
We note that many of the documents included in the
attachments to the submissions on the instant motion are not
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