Phuong K. Nguyen - Page 5




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               By a notice of deficiency dated July 16, 1999 (the notice of           
          deficiency), respondent determined a deficiency in petitioner’s             
          Federal income tax for 1998 in the amount of $2,225.  The                   
          determinations made by respondent in the notice of deficiency               
          mirror those made in the proposed adjustment letter; namely, the            
          change in petitioner’s filing status from head of household to              
          single and the disallowance of the dependency exemptions and the            
          earned income credit as claimed on the return.  The notice of               
          deficiency was issued by the director of respondent’s Atlanta               
          Service Center.                                                             
               After the issuance of the notice of deficiency, respondent             
          reviewed the documentation that petitioner had submitted in                 
          response to respondent’s July 1st letter.  Upon reviewing this              
          material, respondent concluded that petitioner was entitled to              
          head of household filing status, as well as the dependency                  
          exemptions and earned income credit as originally claimed on her            
          return.  Accordingly, by letter dated August 18, 1999 (the no-              
          change letter), respondent informed petitioner that respondent              
          had reconsidered her 1998 tax liability and had accepted her 1998           
          return as filed.  The no-change letter informed petitioner as               
          follows:                                                                    




               3(...continued)                                                        
          for issuing notices of deficiency to taxpayers.                             





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