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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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