- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011