- 5 - a total of $21,267 as “Gross proceeds” ($21,267 of gross pro- ceeds) from broker transactions described as “EMP PLN SHRS SOLD”. Petitioners timely filed a petition with the Court with respect to the 2002 notice. In the petition, petitioners alleged in pertinent part: “The petitioners disagree with IRS in the determination of the deficiency because it was based on the insufficient and inaccurate information.” On September 16, 2004, respondent filed an answer. In the answer, respondent denied that the determinations in the 2002 notice were incorrect and requested “that the relief sought in the petition be denied and that respondent’s determination, as set forth in the notice of deficiency, be in all respects ap- proved.” At various times not disclosed by the record after petition- ers filed the petition in this case, respondent made requests to petitioners for information about the $21,267 of gross proceeds shown in the EquiServe Forms 1099-B. Petitioners did not provide any information or explanation in response to those requests. As discussed above, respondent included in the 2002 notice the address of each payer who provided respondent with an infor- mation return with respect to Mr. Kim or Ms. Kim, including the address of Equiserve shown in the EquiServe Forms 1099-B and the account number for Ms. Kim shown in those forms. Nonetheless, on August 24, 2005, petitioners sent respondent a letter that statedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007