Johnny Elton Kelly - Page 3

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               Respondent determined a deficiency in, and an accuracy-                
          related penalty under section 6662(a) on, petitioner’s Federal              
          income tax (tax) for his taxable year 2000 in the respective                
          amounts of $3,690 and $738.                                                 
               The issue remaining for decision is whether the notice of              
          deficiency (notice) that respondent issued to petitioner with               
          respect to his taxable year 2000 is invalid.  We hold that it is            
          not.                                                                        
                                     Background                                       
               Most of the facts have been stipulated and are so found.               
               Petitioner resided in Memphis, Tennessee, at the time he               
          filed the petition in this case and at all other relevant times.            
               Petitioner filed a tax return for his taxable year 2000                
          (2000 return).  In the 2000 return, petitioner reported wages of            
          $9,246, total Social Security benefits of $18,070, and taxable              
          Social Security benefits of $0 and claimed two dependency exemp-            
          tions, the earned income credit, and head of household filing               
          status.                                                                     
               Respondent’s office in Holtsville, New York, issued to                 
          petitioner a notice relating to his taxable year 2000.  In that             
          notice, respondent determined that petitioner did not have wages            
          of $9,246 as reported in his 2000 return and that he is not                 
          entitled to the two dependency exemptions, the earned income                
          credit, and the head of household filing status that he claimed             






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