Phuong K. Nguyen - Page 4




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          $2,725 to $500, was predicated on (1) a change in petitioner’s              
          filing status from head of household to single and (2) the                  
          disallowance of the dependency exemptions and earned income                 
          credit as claimed on the return.  Respondent informed petitioner            
          that if she did not agree with the proposed deficiency, she could           
          submit documents or information that she wished respondent to               
          consider.                                                                   
               In response to the proposed adjustment letter, petitioner              
          mailed various documents to respondent.  Respondent reviewed this           
          material and concluded that it was insufficient to verify the               
          items under examination.  By letter dated July 1, 1999 (the July            
           1st letter), respondent so informed petitioner.  Respondent also           
          informed petitioner in the July 1st letter that any further                 
          supporting documents or information that petitioner might care to           
          submit would be considered if such material were received within            
          15 days of the date of the letter.                                          
               Petitioner responded to the July 1st letter by mailing                 
          various supporting documents to respondent.  This material was              
          received by the mailroom in respondent’s Atlanta Service Center             
          on July 12, 1999.  The material was routed to the examination               
          division, where it was received on July 13, 1999, and then routed           
          to the 90-day unit, where it was received on July 15, 1999.3                


               3  We understand the 90-day unit to be the office in the               
          examination division of the Service Center that is responsible              
                                                             (continued...)           





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