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in pertinent part:
We received your letter dated August 12, 2005 concern-
ing Stipulation of Facts in preparation of Tax Court
hearing in the case. In order to respond accurately
and diligently in the process, we need the information
and documents in relation to UNREPORTED INVESTMENT
INCOME $21,283.00 including the follows:
- Copies of all IRS documents and reports indicating
petitioners’ Unreported Investment Income $21,283.00.
- Name and address of broker or agent who conducted the
transaction for petitioners in generating the unre-
ported investment income $21,283.00.
* * * * * * *
Since the required process has to be accomplished
without delay, we request your swift response in this
matter. We are unable to attend August 31, 2005 con-
ference with you since we need to contact the bro-
ker/agent and verify the investment income of
$21,283.00. [Reproduced literally.]
On September 9, 2005, petitioners sent respondent another
letter that stated in pertinent part:
We wrote a letter dated August 24, 2005 to you
requesting documents IRS has in relation to the
petitioners’ UNREPORTED INVESTMENT INCOME $21,283.00
and other. We have not received them from you.
Since we do not know what security/stock generated
investment income $21,283.00 and who was the
agent/broker for the sale or transaction in generating
investment income $21,283.00 for petitioners, we need
copies of document and/or report IRS received from
agent/broker or any company as to petitioners’
investment income $21,283.00.
We need agent/broker’s name and mailing address to
contact them to ask how the $21,283.00 investment
income was generated in the case for petitioners.
[Reproduced literally.]
On September 22, 2005, petitioners sent respondent a third
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