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legal authority to support his asserted positions. Also in this
letter, Ms. Gerdine requested that petitioner produce, at such
conference, documentation "to establish facts concerning
[petitioner's] circumstances that were mentioned in the Tax Court
petition" and "to substantiate [petitioner's] filing status,
dependent and expenses mentioned in the Tax Court petition."
The appeals conference was held on April 17, 1996.
Petitioner's attorney presented documentation supporting the
deductions and dependency exemption claimed by petitioner.
Petitioner's attorney informed Ms. Gerdine that he had requested
additional documentation from third parties and would forward
such information to her upon his receipt of the same. Two days
later, petitioner's attorney forwarded this additional
documentation to Ms. Gerdine, including job descriptions and
invoices of payments from the Seton Medical Center to petitioner
in 1992.
Based upon the appeals conference and the substantiating
documentation submitted by petitioner, the case was settled. In
the settlement, petitioner agreed that he had received $31,598 in
income during 1992, and that he was entitled to a $3,000 standard
deduction for that year. Respondent agreed to allow petitioner
(1) a dependency exemption for his son in the amount of $2,300,
(2) Schedule C expenses in the amount of $22,059, (3) a loss of
$962 resulting from the repossession of his car, and (4) a
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