- 5 - After application of the annual exclusions and unified credit, these adjustments resulted in a total proposed 1996 gift tax liability of $371,792. Petitioner filed a written protest to the proposed changes, acknowledging that they pertained to his gift tax liability for 1996. Because further correspondence failed to yield any agreement between petitioner and respondent on the valuation issues, on March 20, 2000, respondent mailed to petitioner at his last known address a statutory notice of deficiency. The deficiency notice indicated that it was for tax year ending December 31, 1995, and asserted a gift tax deficiency for 1995 in the amount of $367,623, the same amount stated in the 30-day letter for 1996 that was previously sent to petitioner. Petitioner received the deficiency notice on March 22, 2000. Attached to the cover page of the deficiency notice was a Form 4089-c, Notice of Deficiency--Waiver, a Form 3615-A, Explanation of Tax Changes, and an additional schedule detailing the revisions to the values of the transferred partnership interests. The Form 4089-c and the Form 3615-A both referred to a tax year ending December 31, 1995. The Form 3615-A contained figures corresponding to the 1996 gift tax return filed by petitioner as well as the examiner’s report for 1996 gift tax. The additional schedule contained no reference to the taxable period, but it detailed the gift transactions made by petitioner on December 26, 1996, andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007