James Edward Briggsdaniels - Page 7




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          and age requirements of section 32(c)(1)(A), but is subject to              
          the phaseout limitations of section 32(a)(2).                               
               For the 1997 tax year, the earned income credit is                     
          completely phased out under section 32(a)(2) for an individual              
          with no qualifying children if the taxpayer’s earned income and             
          adjusted gross income is over $9,769.  Petitioner’s earned income           
          and adjusted gross income was $21,994 in 1997.  Petitioner is               
          therefore not entitled to the earned income credit for the 1997             
          tax year.  For the 1998 tax year, the earned income credit is               
          completely phased out under section 32(a)(2) for an individual              
          with no qualifying children if the taxpayer’s earned income and             
          adjusted gross income exceeds $10,029.  Petitioner’s earned                 
          income and adjusted gross income in 1998 was $18,479.  Petitioner           
          is therefore not entitled to the earned income credit for the               
          1998 tax year.                                                              
               At trial, petitioner made no offer of proof of any relevant            
          facts that would tend to support his claims.  His brief contains            
          no legal arguments that would have any bearing on the outcome,              
          much less tend to support any of his claims.  In Briggsdaniels v.           
          Commissioner, T.C. Memo. 2000-105, affd. without published                  
          opinion 248 F.3d 1169 (9th Cir. 2001), we entered decision                  
          sustaining respondent’s determinations that petitioner was not              
          entitled to head of household filing status, dependency                     
          deductions, or the earned income credit for the taxable years               






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