Sue Taylor - Page 22

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         the effective and efficient enforcement of internal revenue laws.            
         Consequently, the partnership items of such partner, arising in a            
         partnership taxable year ending on or before the last day of the             
         taxable year of the partner for which a deficiency notice based              
         upon an indirect method of proof is mailed to the partner, shall             
         be treated as nonpartnership items as of the date on which the               
         deficiency notice is mailed.  Therefore, respondent was not                  
         required to issue National Land Bank an FPAA before mailing the              
         statutory notice of deficiency to petitioner.                                
              D.   Miroyal Income                                                     
              At trial, petitioner asserted the Fifth Amendment privilege             
         and refused to admit or deny whether she provided real estate                
         services in 1999 and 2000.  Similarly, petitioner refused to                 
         confirm or deny whether she managed real property in 1999 and                
         2000 on the same Fifth Amendment reasoning.                                  
              Respondent for lack of substantiation disallowed Miroyal’s              
         claimed deductions for 1999 as follows:  $20,165 for repairs and             
         maintenance, $15,696 of interest, and $14,107 of other deductions            
         (i.e., insurance $5,913, miscellaneous $6,351, and utilities                 
         $1,843).  Petitioner signed Miroyal’s 1999 and 2000 Federal tax              
         returns, naming herself the tax matters partner for 2000, yet she            
         provided no receipts or records but provided only a typed list               
         showing the total amounts Miroyal allegedly expended on the                  







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