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years 1995, 1996, and 1997. The notices reflected the following
basis for the disallowance:
The income on the W2s on your 1995, 1996, and 1997 returns
was never reported to the Internal Revenue Service by any of
the employers listed. You failed to produce any
documentation to support the W2 income claimed. We are
disallowing the income claimed attached to the W2s filed
with your 1995, 1996, and 1997 tax returns.
Based upon the disallowance of the income, respondent also
disallowed the earned income credits claimed by petitioner in
each year. The first pages of the notices of deficiency
reflected the following total deficiency amounts, calculated
using the respective credit adjustments:
1995 1996 1997
Earned Income Credit Adjustment $1,794 $2,117 $2,210
Withholding Credit Adjustment 1,671 1,995 2,441
Deficiency 3,465 4,112 4,651
Pursuant to Orders of this Court, these cases were dismissed for
lack of jurisdiction insofar as they related to the withholding
tax credits. See generally sec. 6211(a) and (b)(1); Redcay v.
Commissioner, 12 T.C. 806 (1949). These dismissals reduced the
amounts of the deficiencies at issue in these cases to $1,794,
$2,117, and $2,210 for each respective year.
The first issue for decision is whether there are
deficiencies at issue in these cases. Petitioner argues that
there are no deficiencies in these cases within the meaning of
such under sections 6211, et seq.
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Last modified: May 25, 2011