Walter A. and Alfreda Kocot - Page 7

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          adjusted gross income did not change, and therefore their overall           
          tax liability should not change; (3) respondent employed a “slip            
          shod” method of examination, resulting in petitioners’ receipt of           
          “four” notices of deficiency; and (4) petitioners were unjustly             
          given only “three days” to file their petition with the Tax                 
          Court.  For reasons stated herein, we find that petitioners have            
          not sufficiently proved these claims, that the total amount of              
          Social Security benefits received by petitioners in 2002 (line              
          20a) was $28,622, and that petitioners are not entitled to any              
               First, petitioners assert that the amount in deficiency                
          determined in the August 30, 2004, notice of deficiency is                  
          incorrect because respondent failed to account for petitioners’             
          $8,000 in estimated tax payments.  However, in the June 16                  
          letter, respondent acknowledged petitioners’ total payments of              
          $16,699 (a $2,016 payment included with their return, $6,682.75             
          in Federal income tax withheld, and $8,000 in 2002 estimated tax            
          payments).  Subsequent documents, including the April 5 and June            
          14 letters, contain only those items for which respondent                   
          proposed a change.  Since respondent did not dispute or propose             
          any change to the amount of estimated tax petitioners paid in               
          2002, the estimated tax was not included as part of the proposed            
          change computations.                                                        

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