Gary Blore - Page 3




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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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