Ragnhild Anne Westby - Page 2

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               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect at all relevant times, and              
          all Rule references are to the Tax Court Rules of Practice and              

               Respondent determined against petitioner tax deficiencies              
          for 1988 and 1989 in the respective amounts of $59,032 and                  
          $72,150.  The tax deficiencies related to petitioner’s income and           
          expenses from her solo law practice.                                        
               In 1996, as a resident of Minnesota, petitioner timely filed           
          a petition in this Court disputing the above tax deficiencies               
          that respondent had determined in petitioner’s Federal income               
          taxes for 1988 and 1989.  Westby v. Commissioner, T.C. Memo.                
               On December 7, 2004, after a trial and opinion, a decision             
          was entered in the above Tax Court case reflecting major downward           
          adjustments in the tax deficiencies determined against petitioner           
          by respondent; namely, the Court redetermined tax deficiencies in           
          petitioner’s Federal income taxes for 1988 and 1989 of $4,250               
          and $2,635, respectively.                                                   
               On April 8, 2005, respondent assessed the above-redetermined           
          and adjusted Federal income tax deficiencies against petitioner.            

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