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adjusted gross income did not change, and therefore their overall
tax liability should not change; (3) respondent employed a “slip
shod” method of examination, resulting in petitioners’ receipt of
“four” notices of deficiency; and (4) petitioners were unjustly
given only “three days” to file their petition with the Tax
Court. For reasons stated herein, we find that petitioners have
not sufficiently proved these claims, that the total amount of
Social Security benefits received by petitioners in 2002 (line
20a) was $28,622, and that petitioners are not entitled to any
overpayment.
First, petitioners assert that the amount in deficiency
determined in the August 30, 2004, notice of deficiency is
incorrect because respondent failed to account for petitioners’
$8,000 in estimated tax payments. However, in the June 16
letter, respondent acknowledged petitioners’ total payments of
$16,699 (a $2,016 payment included with their return, $6,682.75
in Federal income tax withheld, and $8,000 in 2002 estimated tax
payments). Subsequent documents, including the April 5 and June
14 letters, contain only those items for which respondent
proposed a change. Since respondent did not dispute or propose
any change to the amount of estimated tax petitioners paid in
2002, the estimated tax was not included as part of the proposed
change computations.
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